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Seminar & Training Program DDTC Maret-April 2014

Informasi buat teman-teman yang akan mengikuti Seminar & Training di DDTC

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DANNY DARUSSALAM Tax Center proudly presents ‘tax knowledge elevating training’    
with topics covering:

Seminar on Transfer Pricing: Transfer Pricing Audit and Case Law

                                                     (Tuesday, 25 March 2014)

Seminar Description:

Transfer pricing (‘TP’) has been noted by the Directorate General of Taxes (‘DGT’) as specific area where enforcement been increased for compliance purpose. In recent years, DGT have issued several tax regulations concerning transfer pricing, and the pinnacle is the transfer pricing audit standard governed in DGT regulation No.  PER-22/PJ/2013 (‘TP Audit Standard’) and its implementing instruction for tax auditors set out in DGT Circular Letter No. SE-50/PJ/2013 (‘Auditor’s TP Audit Manual’).

TP Audit Standard confirms the application of arm’s length principle accordingly with international best practices, and covering almost every complex transaction including:

a. intra-group services
b. use or transfer of intangible property
c. intra-group financing

TP Audit Standard also introduced other transfer pricing methodology to be used on the use or transfer of intangible property, namely income based approach, cost based approach, and market based approach. It also increases the coverage area of information to the affiliated parties of the relevant supply chain. In addition to the new features above, the Auditor’s TP Audit Manual also introduces the use secret comparable in TP analysis.

Prior to TP Audit Standard and Auditor’s TP Audit Manual, DGT have ruled out ‘Application of Arm’s Length Principle Rules’ set out in DGT regulation No. PER-43/PJ/2010 (issued on 6 September 2010) latest amended by PER-32/PJ/2011 (issued on 11 November 2011). The Application of Arm’s Length Principle Rules also confirms the application of arm’s length principle based on international best practices, and includes also ‘Cost Contribution Agreements’ besides the above mentioned complex transaction as area of application.

Further to the Transfer Pricing Rules mentioned above, the question arises,

  • Whether the Application of Arm’s Length Principle Rules (PER-43 and PER-32) could be applied for tax years prior its issuance date?
  • How to manage flow of information to substantiate the affiliated transactions, how much is enough and how much is too much?
  • How to relate the Indonesian Transfer Pricing Rules to the International Best Practices?
  • How TP international best practices be helpful in defending your TP positions?
  • What is the view of tax auditors or tax court judges concerning International Best TP Practices?
  • In cross-border transaction, how to relate Transfer Pricing rules with International Tax rules?
  • Where to settle the dispute, tax audit stage, ‘mutual agreement procedure’, objection, appeal, or even civil review, and what is the likelihood of success in each of those stages?
  • In the end, how to manage transfer pricing audit and defend your company’s transfer pricing tax position?

To find out and discuss the above issues and many other transfer pricing audit and dispute issues, or even to discuss your company’s transfer pricing disputes, meet DANNY DARUSSALAM Tax Center’s multi-disciplinary tax experts in our seminar. Our tax experts’ credits are proven with vast track records with high rate of success and work product quality in tax audit, objection and court proceedings, also with in-depth knowledge of their multi-disciplinary knowledge.

click for more details


  • Rp 3.000.000,- (Seminar kit, Updated hardcopy material, Certificates, Coffee break and meals, Library access, and others modern supporting facility)
  • Early Bird Discount: 15% discount is given for registration before 12 March 2014

International Taxation Course – Executive Class

(Start on 12 April 2014 – Finish on 10 May 2014)

Course Description:

The increase in cross-border trade and globalization has required tax professionals and tax authorities alike to operate on a multinational level, where knowledge of domestic law is inadequate. This course offers participants with a comprehensive knowledge on international tax law principles and practices, where the role of tax treaties has become even more important in resolving the issues of juridical double taxation and double non-taxation including planning international tax opportunities.

Our International Taxation Class offers a comprehensive guide to the study of international taxation for tax practitioners, tax specialist in commerce and industry, attorney, and finance professionals involved in international tax matters. Student with relevant discipline background are also welcome to join. Although, this executive class has the same basic structure with the regular class, however, we also enhance more practical skills and guidelines on how to manage international tax implications on cross-border transactions.

click for more details


  • Rp. 6.500.000,- (Including hand-out, Reading materials, Certificates, Coffee break and meals, Library access, and others modern supporting facility)
  • 15% discount is given for registration of two or more participants

*This training and seminar are limited to only 25 participants*

Further Information and Registration:

Seminar and Training are offered in Bahasa Indonesia and held in DDTC’s Training Center:
Menara Satu Sentra Kelapa Gading
6th floor (Unit #0601)
Jl. Boulevard Kelapa Gading LA3 No.1
Summarecon, Kelapa Gading
Jakarta Utara 14240

For further enquiries, please contact:

Ms Eny Marliana
Mobile :  +62 815 898 0228
Email  :

Ms Indah Kurnia
Mobile  : +62 856 192 6643
Email   :

For more information about our company, please visit our website at

Past Course and Seminar:

Former Participants’ Testimonials


Please Download the Registration Form Here

(PT Dimensi Internasional Tax)

Menara Satu Sentra Kelapa Gading
5th floor (#0501) & 6th floor (#0601)
Jl. Boulevard Kelapa Gading LA3 No. 1
Summarecon, Kelapa Gading
Jakarta Utara 14240

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Phone: +62 21 2938 5758
Fax: +62 21 2938 5759





April 10, 2014 - Posted by | Adv. Seminar

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