Final Session of DDTC Academy’s TP Course Batch 32 Concluded

DDTC ACADEMY concluded the final session of its intensive course titled Comprehensive Transfer Pricing Batch 32 on Saturday (1/11/2025). Overall, the programme consisted of 4 learning sessions, with 1 final exam session scheduled for the following week.

Regarding the exam, participants who achieve a minimum score of 70 out of 100 will receive an e-certificate of excellence. This e-certificate of excellence serves as proof that participants have mastered the fundamental concepts of transfer pricing.

In the fourth session, materials were delivered by two DDTC professionals: Manager of DDTC Consulting, Tami Putri Pungkasan, S.E., BKP., ADIT. and Assistant Manager of DDTC Consulting, Dwina Karina, S.H., BKP., ADIT.

The session began with a discussion on the transfer pricing aspects of intra-group services. Topics included identifying the arm’s length nature of such services, identifying benefits and conducting benefit tests for intra-group service transactions.

The discussion then shifted to the application of the arm’s length principle (ALP) in business restructuring. The speakers emphasized the importance of considering tax implications arising from changes in economic structures, functions and risks within a business group.

The session continued with an overview of new transfer pricing audit provisions under MoF Reg. 15/2025. As a closing, dispute resolution mechanisms in transfer pricing were discussed, including the advance pricing agreement (APA) and mutual agreement procedure (MAP).

All materials in this intensive course were enriched with case law analysis, providing concrete illustrations of how the ALP is applied in transactions between affiliated parties. Overall, the course is expected to help participants build a strong understanding of transfer pricing fundamentals.

Such understanding is crucial for taxpayers engaged in controlled transactions, enabling them to mitigate tax risks and potential disputes in the future.

On another note, for participants’ convenience, recordings of all training sessions will remain accessible on the DDTC Academy website dashboard until 15 November 2025, allowing them to review the materials and prepare for the final exam.