Every fact is sourced. Every calculation is reproducible. Every judgment is documented. AI reads and drafts, deterministic code runs the calculations, and a licensed tax firm reviews the work and signs the final report.
Request a ConsultationNet revenue from related-party distribution reached IDR 2,431.5 bn in FY2024, of which the majority was transacted with affiliated counterparties.
Trace each fact to the exact source, reproduce every calculation, and review the rationale behind each judgment. Nothing in the report exists without a record of where it came from.
A licensed tax consultant from the Librantic partner network reviews the methods and comparable decisions, then signs the final report. You receive documentation a professional has put their name on.
AI extracts and organizes the source material while your partner firm manages the process, involving your team only when context or judgment is needed.
Your partner firm manages the engagement. Librantic handles the document production in the background.
Your partner firm identifies the entities and related-party transactions that require documentation.
Provide your financial statements, tax returns, related-party agreements, and supporting records to the firm.
Librantic extracts the facts, maps the transactions, and runs the calculations. Your tax consultant involves you when additional context or approval is needed.
Your tax consultant reviews and signs the final report. You receive the documentation together with its supporting sources, calculations, and decision record.
Each part of the process is handled by the tool or professional best suited to it.
AI extracts facts with citations to the exact source. A separate model checks each drafted claim against its evidence. No model gets to mark its own homework.
Calculations run through deterministic code using exact decimal math. The final report accepts numbers only from the calculation engine. The AI never does arithmetic.
A licensed tax consultant reviews the facts, selects the method, evaluates comparable companies, resolves exceptions, and signs the final report. Every decision is recorded and cannot be silently changed.
Transfer pricing documentation follows one international skeleton and many local rulebooks. The OECD three-tier standard defines the structure; each jurisdiction’s regulation defines what a defensible file must contain. Librantic encodes both, so the same controlled system produces documentation that holds up locally.
Live in Indonesia. Our first jurisdiction.
Practical guidance for tax and finance teams, jurisdiction by jurisdiction. Understand what changed, who it affects, what to prepare, and when to act. No 40-page regulatory detour required.
Turnover is only one factor in determining TP documentation obligations. Check the reference year, related-party transaction values and counterparty jurisdictions to assess your company’s requirements.
Document availability, the tax-return summary and submission upon a DJP request are separate obligations. Understand the deadlines and plan your documentation work.
Contracts and invoices alone do not establish whether related-party services were delivered, needed and beneficial. Learn what evidence to prepare and how to connect it to the charge.
A benchmark needs more than a list of company margins. Learn how to document comparable selection, apply Indonesia’s local-comparable preference and calculate a range reviewers can assess.
Complete a short form about your company, related-party transactions, number of entities, and deadline. We route your request to a partner firm, where a licensed tax consultant will contact you to confirm the scope, timeline, and fee.
Transfer pricing documentation is the formal record that demonstrates a company’s transactions with related parties were priced at arm’s length. Under the OECD three-tier standard it typically consists of a master file, a local file, and, for large groups, a country-by-country report. Tax authorities request it during audits to verify related-party pricing.
Under PMK-172/2023, Indonesian taxpayers must prepare a master file and local file if they conduct related-party transactions and exceed thresholds based on gross revenue or the value of those transactions, or if the counterparty is located in a jurisdiction with a lower tax rate than Indonesia. Which entities are in scope depends on each group’s structure, so scoping is confirmed with a licensed tax consultant.
Under PMK-172/2023, the master file and local file must be available within four months after the end of the fiscal year, and the taxpayer summarizes their availability in a statement attached to the annual corporate income tax return. Documentation prepared after the deadline risks being disregarded during an audit.
If documentation is missing, late, or inadequate, the tax authority may disregard it and determine arm’s length prices using its own analysis, which can lead to transfer pricing adjustments, additional tax, interest, and penalties. Documentation prepared contemporaneously and supported by evidence is the primary defense in a transfer pricing audit.
No. In Librantic, AI reads source documents and drafts text with citations, deterministic code performs all calculations, and a licensed tax consultant from a partner firm reviews the analysis, makes the professional judgments, and signs the final report. The AI never does arithmetic and never signs anything.
A local file is typically prepared from audited financial statements, the corporate income tax return, related-party agreements, invoices and supporting records for intercompany transactions, and information about the group’s structure and business. Your partner firm confirms the exact list for your entities before work begins.
You still work with a licensed tax consultant; Librantic is the production system behind them. The firm advises, reviews, and signs, while the platform extracts facts with citations, runs calculations through deterministic code, and keeps a record of every decision, so the documentation is produced faster and every conclusion in it can be traced to its source.
Every report is designed for audit defense: each fact cites its source document, each calculation can be reproduced from the calculation engine, and each professional judgment is recorded with its rationale. The report is reviewed and signed by a licensed tax consultant, and the underlying evidence trail is delivered together with the documentation.
Run a transfer pricing practice without building one. Librantic prepares the analysis; your firm advises, reviews, and signs.