40. In accordance with pmk 22/2020, the annual compliance report is not necessarily presented as a separate document. The agreements contained in the APA within the meaning of Section 1 must be expressed in the Indonesian taxpayer`s transfer pricing policy and included in the transfer pricing documents for the APA period. 45. In some cases, the APA may provide for a review of its conditions in certain circumstances; For example, some change in the structure of the business or the economic situation complicates the application of the agreed methodology. Therefore, the agreement can be amended with the agreement of the parties to resolve this difficulty. In such cases, the APA may be revised in accordance with Article 19 of pmK-22/2020, which is carried out by the implementation of the provisions of Article 6 (verification of comprehensiveness and eligibility) to Article 15 (negotiation). 38. The request for unilateral negotiation of the APA mentioned above must be submitted to the Director General of Taxes by the Director of International Taxation no later than ten (ten) working days from the date of the written notification that the bilateral APA has resulted in disagreements or ended. 21.
An APA will be effective for a specified period from the effective date set out in the agreement. The subject should propose a time limit to the APA taking into account the period during which the method of dealing with relevant transfer pricing issues should be considered appropriate. The APA period may be granted for unilateral and bilateral APAs for up to 5 (five) fiscal years. In its application, the applicant determines the content of the APA. The application must define the scope of both time and substance. In addition, it is worth mentioning the other countries with which a pre-agreement on transfer pricing is to be concluded. If an applicant requests a multilateral APA (with more than two participating states), the APA consists of several bilateral APAs. 34. As stipulated in the applicable tax contract, any agreement reached under the POP is transposed into national legislation, regardless of any time limitation.
Bilateral and multilateral APAs are generally bilateral or multilateral, i.e. they also enter into agreements between the subject and one or more foreign tax administrations under the control of the Mutual Agreement Procedure (POP) under the tax treaties.  The subject benefits from such agreements, since he is assured that income from covered transactions is not subject to double taxation on the part of the IRS and the relevant foreign tax authorities.