According to The Ministry of Finance decree no. 213/PMK.03/2016, a Taxpayer who transacts with a party with a transaction value exceeding Rp 20.000.000.000 for tangible assets and more than Rp. 5.000.000.000 for intangible assets in 1 (one) year for each counter-party transaction in the previous fiscal year, then the Taxpayer should prepare the documentation of the said transaction. ET Consultant has been involved in Local and Master file creation for years, and thus we are eager to assist you in your affiliation transaction documentation. In addition, we will also help with fair pricing strategies in case you are going to perform a rearrangement for profit maximization. Of course, these decisions are still within the safe corridor of taxation rules of law.