Currently, the most key issue is transfer pricing risks. Those risks are mitigated through understanding, planning, and compliance with tax regulations. Taxpayer already faced the problems on intro-group sale and purchase transactions, related parties’ loan, salary and rental rates which was resulted of tax reassessments by tax officer.
In 2017 Ministry of Economic & Finance issued Prakas on Determination of Revenue & Expenditure of Related Parties which covered on arm’s length analysis, arm’s length range, method to apply arm’s length transaction, intra group services, and documentation.