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Abstract
To accommodate the organizational changes in the Indonesian Directorate General of Taxes, the need to improve legal certainty and simplify procedures, and to align with the minimum standard of BEPS Action 14, Indonesia enacted new regulations on MAP and APA, namely Minister of Finance Regulation No. 49/PMK.03/2019 and Minister of Finance Regulation No. 22/PMK.03/2020, respectively. The promulgation of both regulations was followed by the issuance of Director General of Taxes Regulation No. 16/PJ/2020 and Director General of Taxes Regulation No. 17/PJ/2020, as the technical guidance for both ministerial regulations. This article sets out the general principles of this guidance, their new features compared to the old guidance, as well as the assessment of their alignment with the BEPS Action 14 minimum standard. It also elaborates on some remaining challenges in Indonesia’s MAP and APA regime after the promulgation of these regulations.
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