Practice area

World TP Reviews

Transfer pricing

Danny Septriadi is the head of the transfer pricing department at DDTC. He has served as expert witness at tax court for transfer pricing cases such as PT Krafts Indonesia and PT General Food Industries. The team has 15 professionals who have certification in transfer pricing practice. The firm provides a wide range of transfer pricing services, including documentation, transfer pricing risk management and planning, public advocacy, policy considerations, APAs, MAPs, audit defence, litigation and drafting legal agreements. The firm also published the book about transfer pricing practice, which has been used as reference by tax authorities and taxpayers.

DDTC assisted a client with reviewing and formulating a transfer pricing price / margin setting policies. The client is a player in the telecommunication and digital industry in Indonesia and a part of a multinational enterprise group based in Qatar. In this case, DDTC has reviewed and implemented transfer pricing approaches, involving comparable uncontrolled price, using internal and external comparables, and transactional net margin method.

In 2017, Yurike Yuki, Shofia Maharani, Admar Jamal Jr, Azim Novriansa and Annisa Sakdiah joined the firm as specialists in transfer pricing services. In 2018, Resya Famelia Aniqoh joined the firm.


Roy David Kiantiong leads the transfer pricing practice at Deloitte. The team provides services including transfer pricing planning, compliance documentation, transfer pricing litigations, APAs and MAPs cases. Deloitte also assists clients with matters in relation to BEPS, and has hosted BEPS events and industry sessions. They connect with the tax authorities on transfer pricing matters and provide support in the design and implementation of audit defence strategies in dispute resolution.


Jonathon McCarthy leads the transfer pricing practice at EY. The team provides services including strategy and policy development. The team advises clients on controversy risk assessment and management, remediation or mitigation and global transfer pricing controversy. They also support governance optimisation and decision-making processes to help clients reduce the impact of year-end adjustments and transitions to new documentation requirements.

In the past year, Jonathon McCarthy assisted an agri-business group with preparing transfer pricing documentation. This case included more than 32 companies and a large number of transactions. It required a high degree of competence to understand the inter-connection between tested transactions and coordination between engaged team members.

GNV Consulting Services

Dewa Nugraha is the head of the transfer pricing department at GNV Consulting Services. He has more than 16 years of experience in tax consulting. He has knowledge of national and cross-border issues and risks involving transfer pricing issues. Dewa Nugraha also advises clients on developing or managing transfer pricing documentation. The team helps clients across various industries, including trading and manufacturing, energy and resources, banking and financial services, telecommunication, media and technology.

In the past year, Charles Oetomo and Felic Setiawan assisted Decathlon with three-tiered transfer pricing documentation and transfer pricing planning. The team also educated the client on the compliance requirements and tested the inter-company pricing policy to prove that there was no transfer pricing contributing to the loss position.

In 2017, the firm expanded by hiring Felic Setiawan and Wirawan Sasongko. Felic Setiawan works as a director and Wirawan Sasongko works as a manager.

Hadiputranto Hadinoto & Partners

The transfer pricing department is led by Ponti Partogi at Hadiputranto Hadinoto & Partners. Its practice includes transfer pricing litigation, dispute resolution and documentation. The firm advises clients on defending transfer pricing methods during legal actions. It has also contributed and helped implement unilateral, bilateral and multilateral APAs for a wide range of companies. 

Ponti Partogi, Niken kristalia and Nalphian Seotang are assisting a client with a transfer pricing issue. The Indonesian tax authorities imposed corrections on most of the related party transactions of the client, including sales revenue, royalty expenses, interest expenses and intercompany service fees. In this case, the firm proposed its argument based on the tax regulations and the legal and business aspects of the matter. The firm also discussed the technical transfer pricing issues, including the procedures of comparable companies selection, for defending the client’s transfer pricing documentation.


Iwan Hoo leads the transfer pricing practice at KPMG. The team includes several professionals with overseas qualifications who major in international tax. The team holds several seminars related to new transfer pricing rules and deals with specific groups in certain industries. The firm also organises seminars on gaining the knowledge of new regulations for domestic and foreign conglomerates.

Iwan Hoo and Aaron Bruiner are assisting an Indonesian state-owned oil and gas company with transfer pricing documentation. The client has several subsidiaries in the upstream, downstream and other businesses. It required a transfer of knowledge and the application of modular approach to optimise work streams. In the past year, Iwan Hoo also advised a client, an Indonesia subsidiary of a Japanese transportation company, on the matter of using an external comparable. The tax court finally accepted the use of comparable information, although it was mainly from outside this region in the absence of local data.

MUC Consulting Group

Wahyu Nuryanto is the head of transfer pricing and international tax department at MUC Consulting. The transfer pricing team comprises one partner, four managers and 20 transfer pricing consultants. In addition, the department is also supported by six consultants who have transfer pricing certificates from the Chartered Institute of Taxation (CIOT), UK since 2011.

In the past year, Wahyu Nuryanto assisted an automotive manufacturing company with the transfer pricing issues valued at $ 9 million. MUC Consulting convinced the judges that using multiyear data analysis in transfer pricing was more accurate and reasonable because the economic condition and product life cycle of the client is unique. The result was that the client can eliminate the potential tax risk regarding different perception in analyzing the data in relation to transfer pricing issue. 

In 2017, Galih Gumilang and Tigor Mulia Dalimunthe joined the firm as a transfer pricing manager. M. Arif Darmawan joined the firm as a transfer pricing senior consultant.

RSM Indonesia

The team specialises in general tax compliance, corporate tax advisory and transfer pricing. RSM Indonesia has set up four strong sector groups in the development of their industry, including in the government sector, energy sector, financial services sector, real estate and construction sector. The firm is a member of the RSM network.

In 2017, the firm has expanded by hiring Angela R Kusumaningtyas as a manager of tax and transfer pricing.

SF Consulting

Sri Wahyuni Sujono is the head of the transfer pricing practice at SF Consulting. The practice includes transfer pricing disputes and compliance. The firm also assists clients with preparing transfer pricing documentation involving local file and master filing.

Sri Wahyuni Sujono and Achmad Rifai advised PT Bukit Asam on transfer pricing documentation preparation, including master file and local file. The team prepared a wide range of information for master file documentation, including group business activities, group structure, supply chain and functional profiles of the group, and contractual obligations of the group. In addition, the firm also helped its client prepare the benchmarking analysis of related party transactions, from coal transactions, services, and interest within the group for local file documentation.

SF Consulting hired Joko Susilo, who once worked from Tax Prime, as a supervisor TP in 2018.

Client feedback

“SF Consulting works professionally. SF have a very good team who do their detailed reviews and offer services which are suitable with client needs and provide practical solutions. For example, out company is always in an overpayment situation for corporate income tax due to the prepaid income tax on the importation of its raw material. Our previous consultant never offered to file an import income tax exemption in order to minimise or avoid corporate income tax overpayment. SF Consulting found out this situation and offered to process an import income tax exemption which was successfully obtained for 2017.”

“Very professional, good knowledge in tax regulation and consulting, and objective in their work.”

“The strengths of the firm are that the teamwork is solid. If I had to pick a weakness, it would be the relationship with the client.”