Indonesia has fully implemented the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13 recommendations, including Country-by-Country Reporting (CbCR). As a member of the OECD Inclusive Framework, Indonesia has aligned its domestic tax laws with international standards to enhance tax transparency and counter tax avoidance by multinational groups.

This guide provides a detailed overview of Indonesia’s CbCR obligations, including filing thresholds, deadlines, penalties, and useful resources for multinational groups operating in or through Indonesia.

Legal and Regulatory Framework

• Implementing Authority:
  Directorate General of Taxes (Direktorat Jenderal Pajak – DGT)
• Primary Legal Basis:
  • Minister of Finance Regulation No. 213/PMK.03/2016
  • Director General of Taxes Regulation No. PER-29/PJ/2017
• OECD Participation:
  • Member of the OECD Inclusive Framework on BEPS
  • Signatory to the Multilateral Competent Authority Agreement (CbC MCAA)
  • Participates in the automatic exchange of CbC reports with over 70 jurisdictions

Who is Required to File?

Ultimate Parent Entity (UPE) in Indonesia

• Required to submit a CbC Report if:
  • The group’s consolidated annual revenue exceeds IDR 11 trillion (approx. EUR 750 million) in the preceding fiscal year.

Constituent Entities in Indonesia

• Required to file a notification to the DGT, stating:
  • Whether they are the reporting entity;
  • The identity and jurisdiction of the reporting entity.
• Secondary filing obligations may arise if:
  • The UPE is not in a jurisdiction with CbCR requirements;
  • No exchange agreement exists with Indonesia;
  • A systemic failure in exchange occurs.

CbCR Notification Requirements

• Deadline:
  Must be submitted no later than the end of the fiscal year for which the report applies.
• How to File:
  Through the DGT’s online CbCR portal.

CbC Report Filing Requirements

• Deadline:
  Within 12 months after the last day of the fiscal year to which the report relates.
• Submission Format:
  OECD-prescribed XML schema, uploaded via the DGT’s electronic system.
• Content Requirements (per OECD standards):
  • Revenues (related/unrelated parties)
  • Profit/loss before tax
  • Income tax paid and accrued
  • Number of employees
  • Stated capital
  • Retained earnings
  • Tangible assets (excluding cash)
  • Entity list and business activities

Penalties for Non-Compliance

• Failure to submit the CbC Report:
  Administrative fine of IDR 1,000,000
  Further penalties may apply for continued non-compliance.
• Failure to notify:
  May result in penalties ranging from IDR 5,000,000 to IDR 10,000,000.
• Criminal sanctions may also apply for wilful non-disclosure under Indonesia’s tax law.

Transfer Pricing Documentation

In addition to the CbCR, Indonesia requires:

• Master File and Local File documentation
• Threshold: Applicable if annual revenue exceeds IDR 50 billion
• Must be prepared annually, and provided upon request by the DGT

Language and Format

• Documentation and reports must be submitted in Bahasa Indonesia.
• However, English versions may be accepted with DGT approval.

Useful Resources

• Directorate General of Taxes (DGT) – CbCR Portal:
  https://stats.pajak.go.id/en/country-country-report-cbcr
• OECD CbCR Overview:
  https://www.oecd.org/tax/beps/country-by-country-reporting.htm