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Challenges of TP on intangible assets: An Indonesian tax perspective

May 26 2021 Transfer pricing (TP) on the payment of royalty of intangible properties has always been a significant issue for multinational enterprises (MNEs). There are many challenges that must be faced by companies in the context of an arm s-length assessment, especially in the litigation process in Indonesia. Royalty payments are often corrected by the tax office due to doubts and an element of suspicion where renumerations for the use of technical know-how to the parties who have a special relationship are considered to be one of the ways to reduce the profits of companies in Indonesia, especially if the company is still in a loss position.

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