Wirawan Sasongko

Wirawan Sasongko is a Senior Manager in Transfer Pricing at GNV Consulting. He advises national and multinational groups across trading, manufacturing, energy, and financial services, drawing on 10+ years of practice. He began his career at KPMG.

Wirawan holds a Bachelor’s in Accounting from Universitas Trisakti, an MBA (Marketing & Finance) from Universitas Gadjah Mada, and an M.Sc. in Economics & Business (Financial Economics) from Erasmus University Rotterdam.

His work spans the full transfer pricing cycle: policy design and planning; local and master file documentation; compliance; audit defense; and dispute resolution, including Mutual Agreement Procedures (MAP). He is frequently engaged to pressure-test positions, align fact patterns with functional analyses, and structure defensible intercompany pricing under the arm’s-length principle.

Operating with analytical rigor and clear, business-first judgment, Wirawan combines technical benchmarking with pragmatic regulatory navigation to deliver outcomes that stand up to scrutiny—before auditors, in negotiations, and, when necessary, in controversy forums.

• Together with Partner in charge, I lead the transfer pricing team within our tax legal practice, providing strategic advice and backbone arguments in audits and litigation. I’ve steered multiple high-stakes appeals for a confidential regional client from audit through court. My approach is evidence-first: disciplined functional analyses, rigorous comparables, and a litigation-ready narrative. I align CUP/TNMM and comparability adjustments with OECD and Indonesian rules, anticipating and neutralizing revenue-authority positions—delivering durable wins and measurable risk reduction across contested years.
• Together with Partner in charge, I lead the transfer pricing within our tax legal practice, providing audit-ready Local/Master Files, PER-22 filings, and market-tested benchmarking with risk/working-capital adjustments and clear pricing corridors—driving fewer queries and materially lower exposure.
• Together with Partner in charge, I lead the transfer pricing within our tax legal practice, providing end-to-end defense from data room to court: neutralizing broad-brush adjustments, challenging “secret comparables,” and reallocating corrections per transaction to align TP and indirect-tax rules—yielding cancellations/annulments or significant reductions. Cross-border disputes handled through MAP, securing bilateral relief, corresponding adjustments, and pragmatic roll-forwards to prevent repeat double taxation.
• Together with Partner in charge, I lead the transfer pricing within our tax legal practice, assisting clients in the design and implementation TP policies (royalties, services, distribution); advise on transfer pricing restructuring.

• Corporate tax matters: APAs, Restructuring
• Dispute resolution: Audit defence, Dispute resolution, Litigation, MAPs/ADRs
• Transfer pricing: Audit defence, Audit support, Business restructuring, Dispute resolution, International tax planning, IP management, Litigation, TP policy design, TP risk management

• Automotive
• Food and beverage
• Healthcare
• Industrials
• Oil and gas
• Pharmaceutical and life sciences
• Tourism

• Bachlor, Universitas Trisaksi, 2005
• Master of Business Administration, Master of Management Programs from Faculty of Economics and Business at Gadjah Mada University – Yogyakarta, Indonesia, 2013
• Master of Science (M.Sc) in Economics and Business, Economics and Business Programs from Erasmus School of Economics at Erasmus Universiteit Rotterdam – The Netherlands, 2013