Tax Law

We advise on tax compliance, assessments, objections, and appeals before the Tax Court, representing clients through disputes with the tax authority at each stage of the administrative and judicial process — from the initial audit and assessment, through the formal objection that Indonesian tax procedure requires before an appeal may be filed, to the appeal itself and, where the amount or the principle at stake warrants it, judicial review before the Supreme Court.

Tax exposure compounds quietly. A position taken in a single filing year, defensible at the time on a reasonable reading of ambiguous regulation, can surface years later as a substantial assessment once the authority's own interpretation has hardened or diverged from the client's — and by the time it surfaces, the interest and penalties attached to the original position frequently exceed the disputed tax itself. Our role is both preventive and corrective. Preventively, we advise on the structuring of transactions, the documentation of related-party pricing, and the filing positions a client takes, with an eye to how each will withstand scrutiny years after the transaction has closed and the commercial rationale that justified it at the time has faded from institutional memory. Correctively, where a dispute has already arisen, we represent the client through objection and appeal, building the factual and documentary record that a tax dispute — perhaps more than any other area of practice — depends upon almost entirely.

We advise corporate and individual clients alike, recognising that the stakes of a tax dispute are rarely proportionate to its apparent complexity: a modest procedural misstep in responding to an audit can expose a client to an assessment far larger than the error that triggered it, and the difference between a well-managed and a poorly managed tax dispute is measured, more often than not, in the quality of the record built from the very first response to the tax authority's first inquiry.