DDTC and Pertamina Hulu Energi Host IHT on International Tax

DDTC Academy, together with Pertamina Hulu Energi, has held an in-house training (IHT) on international tax and the interpretation of tax treaties (persetujuan penghindaran pajak berganda/P3B in Indonesian). The IHT took place offline at Plaza 89, Jakarta, on Wednesday–Thursday (23–24/6/2026).

This IHT featured 4 DDTC professionals as presenters, including are Senior Manager of DDTC Fiscal Research & Advisory, Denny Visaro, Senior Manager of DDTC Consulting, Riyhan Juli Asyir, and Assistant Managers of DDTC Consulting, Atika Ritmelina Marhani and Dwina Karina.

All four presenters are DDTC professionals who have attained the Principles of International Taxation certification from the Chartered Institute of Taxation (CIOT), United Kingdom. All presenters have been awarded the Advanced Diploma in International Taxation (ADIT).

These credentials demonstrate that the presenters not only command the fundamental and advanced concepts of international tax but also possess a comprehensive understanding of developments in global regulation.

The 20 IHT participants comprised analysts through to managers from the tax division of Pertamina Hulu Energi. This personifies Pertamina Hulu Energi's commitment to strengthening its human resource capacity to respond adaptively to the dynamics of international tax.

Over the two days of training, the presenters covered various aspects of international tax comprehensively. On the first day, the discussion began with an introduction to the fundamentals of international taxation as a foundation for understanding the jurisdiction to tax between countries and the potential rise of double taxation.

Having established the fundamental concepts, the presenters explained the general rules of interpretation, the structure and procedures for the application of tax treaties to enable trainers to read and understand the interpretation and application of tax treaties correctly. In addition, the exemption and credit methods, along with their implications, were also elaborated.

Participants were also equipped with an understanding of several special provisions relating to business profits and permanent establishments (PE). This is crucial as PE status frequently serves as the starting point for determining a country's jurisdiction to tax.

Moving into the second day, the discussion focused on special provisions governed by tax treaties, namely associated enterprises, capital gains on immovable property, capital gains on the indirect transfer of shares, passive income and beneficial ownership.

In addition, participants were guided through various developments in international taxation via the base erosion and profit shifting (BEPS) initiative led by the OECD/G-20. The discussion covered provisions on controlled foreign companies (CFC), thin capitalisation and global minimum tax.

All materials from the first through to the second day were enriched with case studies that provided concrete illustrations of how tax treaty principles are applied in international practice.

Enthusiasm among trainees was evident, as evidenced by the questions raised during the IHT. Further, with the IHT format, participants could ask questions directly relating to the tax aspects of the various transactions undertaken by Pertamina Hulu Energi, resulting in a lively and dynamic discussion.

Through this training, participants gained both conceptual understanding and practical insights applicable to every business process. This is essential for building an international mindset in the formulation of tax management strategies and risk mitigation.

As part of efforts to support the ongoing development of competencies, the presenters also handed over eight books published by DDTC to Pertamina Hulu Energi during the training. The books presented by DDTC are as follows.

1. Persetujuan Penghindaran Pajak Berganda: Panduan, Interpretasi, dan Aplikasi (Edisi Kedua).
2. Konsistensi 21 Tahun Gagasan Pendiri DDTC untuk Pajak Indonesia.
3. Susunan Dalam Satu Naskah UU KUP, UU PPh, dan UU PPN Berdasarkan UU 6/2023 dengan Penyesuaian Ketentuan Pidana dalam UU KUP Berdasarkan UU 1/20266.
4. The Consolidation in a Single Text of the General Provisions & Tax Procedures, Income Tax and Value Added Tax Law Pursuant to Law 6/2023 with Adjustments to the Criminal Provisions under the GPTP Law Pursuant to Law 1/2026.
5. Konsep dan Aplikasi Pajak Penghasilan Edisi Kedua.
6. Konsep dan Studi Komparasi Pajak Pertambahan Nilai Edisi Kedua.
7. Transfer Pricing: Ide, Strategi, dan Panduan Praktis dalam Perspektif Pajak Internasional (Edisi Kedua - Vol 1).
8. Transfer Pricing: Ide, Strategi, dan Panduan Praktis dalam Perspektif Pajak Internasional (Edisi Kedua - Vol 2).

If you are interested in holding a training similar to that of Pertamina Hulu Energi, please apply for personalised training via the DDTC Academy website. In addition to IHT, there is also an IHT-Advisory scheme that merits consideration.

DDTC Academy will also be holding approximately 40 regular programmes in 2026. You can view details of the programmes and schedule in the booklet entitled Rooted, Growing & Trusted. Kindly note that by the end of 2025, more than 16,500 people had become alumni of DDTC Academy programmes.

Do you have inquiries concerning DDTC Academy programmes? Please contact the DDTC Academy WhatsApp Hotline at 0812-8393-5151 (Minda), email [email protected] or via the DDTC Academy Instagram account (@ddtcacademy).