Expert: Discrepancy in Export-Import Data a Red Flag, but Must Be Proven

REPUBLIKA.CO.ID, JAKARTA – The government’s finding regarding discrepancies between crude palm oil (CPO) export and import data should be appreciated as an early signal of potential irregularities in the trade of a strategic commodity. However, the difference in transaction values cannot automatically be taken as proof of transfer pricing or underinvoicing practices.

Everything must therefore be supported by complete evidence. “The difference in values between Indonesia’s export data and the import data of destination countries is indeed a red flag, but it does not automatically prove that manipulation has occurred,” said Ade Holis, Head of Research at NEXT Indonesia Center, in a press statement in Jakarta on Tuesday (15/9/2026).

According to Ade, the government needs to draw a firm distinction between initial indications and legal conclusions. In the context of transfer pricing, he said, the core issue is not merely the existence of a price difference, but whether the transaction prices between related parties satisfy the arm’s length principle.

Ade noted that transfer pricing is not automatically an illegal practice. A violation occurs when prices set in transactions influenced by special relationships do not comply with the arm’s length principle and applicable tax regulations. He said the provisions on the arm’s length principle set out in PMK Number 172 of 2023 must serve as one of the foundations for assessing these allegations.