Following the finalization of the OECD/G-20 BEPS Report Action 13 in October 2015, the Indonesian Ministry of Finance has finally issued a new regulation No. 213/PMK.03/2016 (“PMK-213”) on 30 December 2016, which requires taxpayers with certain conditions to prepare a three-tiered approach to transfer pricing documentation. The new regulation is effective from 30 December 2016 onwards. On this basis, although it is not stated clearly in the regulation, it could be interpreted that the requirements stated within PMK-213 are also applicable for fiscal year 2016, and this would affect taxpayers immediately.