Wibowo Mukti
Wibowo Mukti is a partner with the Tax, Trade and Customs Practice in Assegaf Hamzah & Partners.
Bonnie, as he is known to just about everybody, graduated from the State College of Accounting (STAN) in 1989, before earning his undergraduate degree in economics from the University of Indonesia in 1995, followed by a master’s degree in management, majoring in international management, from the same university in 2000.
He has held the highest tax consultant’s license (Brevet C) and a Tax Court license since 2004. He is a member of the Indonesian Tax Consultants Association and the Indonesian Customs Specialists Association. and he also a member of the Indonesian Bar Association (Peradi).
Prior to joining Assegaf Hamzah, he was President Director of PT Ambalan Handal Prakarsa, a consultancy firm affiliated to Assegaf Hamzah.
Bonnie has more than 30 years of experience in tax-dispute resolution, tax compliance and tax advisory work in the areas of corporate and personal taxation, value added tax, and property taxes and duties. This includes 13 years of experience with the Directorate General of Taxes as a government tax auditor. He spent more than four years with PricewaterhouseCoopers in Jakarta. And he also became a member of Foreign Affairs Department of Indonesian Tax Consultants Association (IKPI) since 2014.
His extensive experience includes assisting clients on a broad range of matters on both the contentious and non-contentious side. Non-contentious matters include M&A transactions, financing and investment in the form of equity and non-equity raising issues both at domestically and abroad, tax advisory work on behalf of corporate clients including international tax planning; transfer pricing; corporate restructuring; and advising clients on the tax implications of both inbound and outbound investments.
On the contentious side, resolution of tax and customs disputes arising from audits; objections/reductions or cancellations of penalties and assessments; tax appeals in the Tax Court and subsequent judicial reviews (peninjauan kembali) in the Supreme Court.
Qualifications
- Diploma in Accounting, State College of Accounting (STAN) (1989)
- Bachelor’s degree in Economic, University of Indonesia (1995)
- Master’s degree in Management, University of Indonesia (2000)
- LL.B., Institute of Business Law and Management (STIH IBLAM) (2014)
- Advocate – the Indonesian Bar Association (PERADI) (2017)
- Tax Consultant – C License Certificate (the Highest Level) (since 2004)
- Customs Expert License (Ahli Kepabeanan) (2009)
- Tax Court Lawyer – Tax (since 2004)
- Tax Court Lawyer – Customs (since 2009)
Memberships / Directorships
- Member of the Indonesian Bar Association (PERADI)
- Member of the Indonesian Tax Consultants Association (“Ikatan Konsultan Pajak Indonesia”/”IKPI”)
- Member of the Board of International Affairs of the Indonesian Tax Consultants Association
- Member of the Indonesian Customs Specialist (“Ikatan Ahli Kepabeanan Indonesia”/”IAKI”)
- Director of Legal and Advocacy Alumni of the State College of Accounting Association (“Ikanas STAN”)
Accolades
- Consumer Attorneys of CaliforniaLegal500 Ranked as Tier 1 (2019-2020)
- Recognized as “Leading Individuals” in Tax by Legal 500 (2019-2020)
- Asialaw 2020: Recommended law firm for taxation (2019-2020)
Recognized as a full-range of tax services tax in both the contentious and non-contentious matters in domestic and cross-border transactions by Chambers and Partners (2020)
Publications
- Aspek Perpajakan Dalam Penerbitan Surat Berharga Syariah Negara (Sukuk Negara) Ijarah – Sale & Lease Back, Jurnal Hukum & Pasar Modal Volume IV/Edisi 5 Tahun 2009. Himpunan Konsultan Hukum Pasar Modal.
- Various AHP Client Updates in relation to Tax, Trade and Customs matters.
Notable Cases & Transactions
- Assisting a large Indonesian cement company in preparing objection letters for its corporate income tax, 2011 Article 26 Withholding Tax, and 2012 Article 26 Withholding Tax, all of which relate to its previous tax years. (2016-ongoing)
- Advised a geothermal joint operating contract company in relation to the government’s share of [what?]. (2016)
- Advising a Singaporean company [in relation to the tax implications of conducting business in a] bonded logistic center (Pusat Logistik Berikat). (2016-ongoing)
- Advised an Italian company on the possible tax liability of their Indonesian representative office. (2016)
- Advising an Indonesian foreign investment company, which is a subsidiary of an American company, on its business expansion plan. (2016-ongoing)
- Represented two British oil and gas companies in branch profit tax appeals before the Tax Court. (2014)
- Representing two British oil and gas companies in a branch profit tax appeals before the Tax Court. (2016-ongoing)
- Representing two British oil and gas companies in four years’ worth of branch profit tax objections against the Indonesian Tax Office. (2016-ongoing)
- Representing a Bermuda oil and gas company in a corporate income tax and branch profit tax objections against the Indonesian Tax Office. (2016-ongoing)
- Representing two British oil and gas companies in several corporate income tax and branch profit tax objections against the Indonesian Tax Office. (2016-ongoing)
- Representing an Australian oil and gas company in a corporate income tax and branch profit tax objection against the Indonesian Tax Office. (2016-ongoing)
- Representing a Canadian oil and gas company in a corporate income tax and branch profit tax objection against the Indonesian Tax Office. (2016-ongoing)
- Advised a large Japanese consumer product company in preparing and submitting a judicial review request to the Supreme Court for a transfer pricing dispute. (2016)
- Prepared a tax legal opinion for a Malaysian Bank regarding ISDA transactions. (2016)
- Advised an Indonesian company in relation to the deduction or withholding of tax under the ISDA 2002 Master Agreement. (2016)
- Successfully represented an Indonesian crude palm oil derivative products company in a customs dispute with the Indonesian Customs and Excise Office. (2015)
- Advised a group of school company in relation to the tax implications of its business restructuring. (2015)
- Advised a large crude palm oil company in relation to the VAT implications of the purchase of fresh fruit bunches from plasma farmers and/or cooperatives. (2015)
- Advised a mutual fund company on its corporate income tax implications from the Limited Participation US Dollar Mutual Funds (Reksa Dana Dollar Penyertaan Terbatas or RDPT). (2015)
- Advised a Hong Kong-based luxurious products company in relation to a customs review of their distribution companies in Indonesia. (2015)
- Advised a PSC company in preparing a response to the Article 4(2) Withholding Tax to the Indonesian Tax Office. (2015)
- Advised an Indonesian geothermal company in preparing a response to the Article 23/26 Withholding Tax of the company’s 2013 tax year to the Indonesian Tax Office. (2015)
- Advised the trading representative office of an American company on the tax implications of its business restructuring. (2015)
- Successfully represented an Indonesian property company in a VAT tax dispute against the Indonesian Tax Office. (2015)
- Representing a Japanese trading company in a corporate income tax objection against the Indonesian Tax Office. (2015-ongoing)
- Successfully represented a geothermal company in relation to a tax audit. (2012-2015)
- Prepared a legal analysis for a large mining company on the status of the payment of withholding tax in relation to past dividend payment to the company’s founding shareholders. (2014)
- Advised a large telecommunication company in relation to preparation of a local tax manual and a customs practice manual. (2014)
- Successfully assisted an American shipping company in settling Article 25 Withholding Tax and Self-Assessed VAT with its Indonesian partner. (2014)
- Represented a trade representative office of a Swedish company in nine years’ worth of tax objections of Article 15 Income Tax against the Indonesian Tax Office. (2014)
- Advised a Singaporean information technology company of the tax Implications of the enterprise mobility solutions (a cloud-based solutions service). (2014)
- Advised an Indonesian crude palm oil derivative products company on a customs review. (2014)
- Represented a large petrochemical company in a customs appeal before the Tax Court. (2013)
- Assisted a hospital in Jakarta in conducting a tax diagnostic review for the tax years of 2010, 2011, and 2012. (2013)
- Successfully represented a large petrochemical company in relation to three customs appeals before the Tax Court. (2013)
- Advised a group of crude palm oil companies in relation to preparation of their annual corporate income tax returns for initial public offering purpose. (2012)
- Successfully represented a geothermal company in three years’ worth of tax audits. (2011-2012)
- Advised a large holding company in preparing appeal letters in relation to the determination of capital gains (Article 26 Withholding Tax) on sales of shares. (2011)
- Successfully represented a large petrochemical company in relation to VAT disputes for two tax years before the Tax Court. (2010)