Principles of Transfer Pricing: Concepts and Application in Indonesia

• Henry Dianto P. Sinaga & Andi Banua Adams
• 2026
• Perpajakan

This book is designed to provide a comprehensive understanding of transfer pricing, from its fundamental concepts and the regulatory framework and practices relevant in Indonesia to the applications and analytical steps commonly encountered in developing transfer pricing policies and preparing transfer pricing documentation. We have sought to present the material systematically, with an emphasis on the link between theory and practice. Readers are guided through functional analysis (functions, assets, and risks), the selection of transfer pricing methods, comparability analysis, the selection of comparables, and issues that frequently arise in specific transactions, such as intra-group services, tangible goods, financing, and the use of intangible assets.

Transfer pricing is often a challenging area for many parties—companies, consultants, academics, and tax officials alike—because it brings together economic, accounting, and legal considerations. For this reason, we have designed this book to serve a diverse readership: students who need a conceptual introduction, practitioners who require guidance on application, and researchers seeking an analytical framework and references to deepen their studies. We hope this book will help readers develop a coherent “transfer pricing mindset”: understanding the transaction, assessing the role of each party, selecting the appropriate method, and documenting the process adequately.