Surrogate Parent Entity

PER-29 also allows an overseas parent entity to appoint a constituent entity within its group as a surrogate parent entity, as long as all the following criteria are achieved :

1. The taxpayer in Indonesia notifies the DGT about which constituent entity is appointed as a surrogate parent entity;
2. The country / jurisdiction where such appointed surrogate parent entity resides obliges its taxpayers to file a CbCR and such country / jurisdiction has a Qualifying Competent Authority Agreement (“QCAA”) with Indonesia; and
3. The appointed constituent entity should be the only entity within the group that is appointed as a surrogate parent entity.