Director General of Taxes Regulation No. PER-29/PJ/2017 (“PER-29”) is an implementing regulation issued by Indonesia’s Directorate General of Taxation (DGT) on December 29, 2017. It details the procedures for the management of Country-by-Country Reporting (CbCR) in Indonesia, supplementing the requirements set out in Ministry of Finance Regulation No. 213/PMK.03/2016.

Key Provisions of PER-29/PJ/2017

Scope and Applicability

• The regulation applies to multinational enterprise (MNE) groups with Indonesian entities, specifically those with related party transactions.
• The Parent Entity of a business group must prepare, maintain, and submit a CbCR if it meets certain criteria, such as controlling other group members and being required to prepare consolidated financial statements under Indonesian standards or stock exchange rules.

CbCR Notification and Submission

• All Indonesian taxpayers that are part of an MNE group covered by CbCR requirements must file a Notification with the DGT, stating whether they are obligated to submit a CbCR and identifying the reporting entity (Parent or Surrogate).
• For fiscal year 2016, the Notification and CbCR submission deadline is 16 months after year-end. For fiscal year 2017 and onwards, the deadline is 12 months after year-end.
• Submission is done electronically via the DGT’s online portal (DJP Online), or manually if the portal is unavailable.

Reporting Requirements

• Indonesian Parent Entities must submit the CbCR along with an additional “Working Paper” table. Foreign-parented groups are exempt from this extra requirement.
• The receipt of CbCR Notification/Submission must be attached to the following year’s Corporate Income Tax Return.
• If corrections are needed, taxpayers can resubmit corrected reports through the same channels.

Exchange of Information

• The DGT will automatically exchange CbCRs with partner countries or jurisdictions that have a Qualifying Competent Authority Agreement (QCAA) with Indonesia.
• The DGT publishes a list of partner countries/jurisdictions with which CbCRs can or cannot be exchanged. If a CbCR cannot be obtained via exchange, local filing by the Indonesian entity is required within three months after the list announcement.

Effective Date

• The regulation applies to fiscal years starting from 2016, with the regulation itself effective from December 29, 2017.

Summary Table: Key Deadlines

Fiscal Year	Notification & CbCR Deadline	Submission Method
2016	16 months after year-end	DJP Online / Manual
2017+	12 months after year-end	DJP Online / Manual

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Compliance Implications

• Failure to submit the required CbCR forms or Notification may result in the Corporate Income Tax Return being considered incomplete, potentially leading to tax penalties.
• The regulation aligns Indonesia’s CbCR requirements with OECD standards and aims to enhance transparency in transfer pricing and tax compliance for MNEs.