Q&A | Mulyono | Tax Litigation

so my name is Dr. Mulano. I’m the managing partner of Mulen Co. So we are basically a specialized tax law firm in Indonesia. we offer end-to-end services for taxation methods to our clients ranging from tax compliance tax advisory, tax planning, transfer pricing and tax dispute matters. so we actually have served our clients over the past I think around 12 to 13 years. our firm we have three partners. So I’m the managing partner. we serve not only

local clients but also multinational clients u mostly investors foreign investors that are actually investing in Indonesia. We help them starting you know from set up the company you know operating reporting their compliance matters as well as you know if there is any tax dispute matters we have them to represent in front of tax authorities as well as in front of the court if there is any tax issues

we We are actually a specialized tax law firm. but however in terms of providing services, taxation services to our clients, we also provide one not only tax knowledge but also accounting, finance and legals matters.

me myself, I’m actually a CPA certified public accountant as well as well as chartered accountant. I’m also have a background in finance. So in terms of providing restructuring services, we can provide a more holistic view not only about tax but also accounting, finance and legal. I myself also practicing not only about tax lawyers but also in standard court regarding criminal and also civil cases. so we actually although we are servicing in terms of

tax but we have also technical expertise in accounting, finance and legal. So therefore all of our clients they can receive an end to end advice in terms of their tax matters in Indonesia. So the type of cases and clients that we usually engage with usually we engage with multinational clients either it’s actually an inbound investments or is actually a local Indonesian company but owned by a foreign shareholders. The typical cases or I would say advice that we provide one is actually related to

the corporate actions. So we advise the clients on the type of corporate actions or the alternative schemes which focus on the tax efficiencies. So the because our primary expertise it’s in tax. So we always provide alternative structure or schemes to our clients so that they can achieve the most tax efficiencies. The second is actually related to related party transactions or transfer pricings. as in Indonesia or elsewhere transfer pricing issues become more prevalent. So we always advise the clients on how

to mitigate the transfer pricing including we also assist in preparation of transfer pricing documentations to find arms length margin on affiliated party transactions. the third one is basically related to corporate tax matters. if the company engage in certain particularly a new business models and they still want to look what kind of tax implications arising from that business. For examples we had advised many clients in the startup industries financial technology, medical technology and and many others. So in these business models

sometimes the tax methods are not that straightforward I would say. So they require the tax advisors to provide them with comprehensive tax assessments on what will be the tax implications on on their business model would be regarding my career highlights and my background. so I I myself basically have a three disciplinary background accounting, finance and legal. I’m a chartered accountant and CPA in Indonesia. I obtained my bachelor degree in accountant and in law. I have triple masters in in finance

in law as well as in notary. I finished my PhD or doctor degree in taxation law. further I am also a licensed tax lawyers and tax consultant in Indonesia. So I can serve both domestic not only individual corporate but also foreign companies that are actually based in Indonesia.

We serve many many clients. there are several notable cases that we handled just for an examples. One is we assisted clients that that were facing a tax confiscation from tax authority. In that particular cases we filed a tax lawsuit on that tax confict tax confiscations from the tax office. We we successfully defended the clients so that the tax court cancelled the tax confiscations for the assets for examples related to the bank account so that the bank account can be accessed and used for the

transactions. So that’s the first one. The second one is related to intragroup transactions. This is actually quite common practice internationally. However, from Indonesian tax office perspective, these these typical transactions either it’s service or royalties or any purchase of goods and sales related to the intercomp transactions are often subject to scrutiny from Indonesian tax office. So we advised several clients on this one as well as successfully defended our clients to cancel the tax office corrections. there are two types of cancellations

usually that we defend our clients. One is regarding the substance of the intrag group transactions to make sure that it is actually can be recognized or deductible as an expenses. The second one is related to the margin. Right? We need to make sure that the tax court agrees that the taxpayers has already paid or received an arms length margin as opposed to the tax office corrections.

So the reasons that me and our firm joins global law experts is that to widen our international exposures for our for our firm. We also want to look for if there are any referrals between our same professions. if there are any other members in other countries that have clients needs in particularly related to Indonesia and tax matters, we can advise and work collaborate together with other professions. as well as the last one of course to increase our presence.

Yeah. and also our credentials that by joining the global law experts we are being seen as a as a panel of experts within our core expertise which is in this case in tax matters.