Comparative analysis of Indonesia’s new Transfer Pricing guidelines against Singapore’s Transfer Pricing guidelines

Indonesia’s new transfer pricing (“TP”) guidelines are enshrined in the Minister of Finance Regulation 172/2023 (“MoFR-172”), which was announced on the 29th of December 2023. MoFR-172 revokes previous MoFR guidance (MoFR-22, MoFR-49 and MoFR-213), all of which have been streamlined and restated in MoFR-172. There are changes to how the TP process, the Mutual Agreement Procedure (“MAP”) and the Advance Pricing Arrangements (“APA”) are implemented in Indonesia, with the aim of enhancing clarity and fairness in business transactions.