Transfer pricing disputes may be resolved through the domestic Objection and Appeal process or, where the dispute involves a transaction with a related party in a country that is one of Indonesia's tax treaty partners, the parties may request double tax relief under the Mutual Agreement Procedures...
objection letter • Cancellation submitted through the DGCE office. Extraordinary submission and cancellation procedures of an objection letter • The DGCE will inform when the portal is inoperable through digital media; and • The DGCE allows the submission, cancellation, and receipt issued of an...
In particular, the global agreement removes the main objection to more aggressively taxing overseas income because other countries have all agreed to adopt similar systems. The concerns that U.S. companies would be less competitive or would try to avoid U.S. taxes by incorporating overseas are ...
This needs to be submitted within 30 days of receiving your notification of your objection being declined. Again, the general SARS waiting periods apply and an appeal can take up to 60 days to be finalised. There have been cases where this has gone on for 3 months and sometimes a year ...