Transfer Pricing vs Customs Valuation: Issues in Indonesia

On 5 December 2025 the Tax Court ruled on a dispute between the Directorate General of Taxes and a taxpayer over an import‑price correction for a related‑party transaction with a foreign affiliate. The court rejected the tax authority’s correction.

The case highlights the gap between transfer‑pricing valuation for tax purposes and customs valuation administered by the Directorate General of Customs and Excise. The World Customs Organization’s 2018 guide notes that alignment is difficult because each regime pursues different objectives and operates under distinct legal frameworks.

Authorities are therefore urged to deepen cooperation through joint audits and unified policies so that definitions, documentation and valuation methods for affiliate transactions can be harmonised. Such coordination is expected to provide legal certainty for taxpayers and improve overall compliance.