CDB - TPD 2017 English

Transfer
Pricing
Documentation
PT CIPTA DWI
BUSANA
Fiscal Year 2017
Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 0

Table Of Contents
LIST OF FIGURES .................................................................................................................................... 4
Chapter I ............................................................................................................................................... 6
Executive Summary............................................................................................................................... 6
1.1 Document Purpose ................................................................................................................... 6
1.2 The Scope of Document ............................................................................................................ 6
1.3 Occupation ................................................................................................................................ 7
1.4 Document Contents .................................................................................................................. 9
1.5 Group Overview ........................................................................................................................ 9
1.6 Controlled Transactions Checked ............................................................................................ 10
1.7 Characteristics of Business ...................................................................................................... 11
1.8 The Most Appropriate Transfer Pricing Method ..................................................................... 11
1.9 Results of Analysis ................................................................................................................... 12
Chapter II ............................................................................................................................................ 13
Business Overview .............................................................................................................................. 13
2.1 CDB Background...................................................................................................................... 13
2.2 CDB ......................................................................................................................................... 14
2.2.1 Summary of CDB ......................................................................................................... 14
2.2.2 Shareholders ............................................................................................................... 14
2.2.3 CDB Organizational Structure ...................................................................................... 15
2.2.4 Production Process of CDB .......................................................................................... 18
2.2.5 CDB Product Description ............................................................................................. 24
2.2.6 Conclusion ................................................................................................................... 25
Chapter III ........................................................................................................................................... 26
Related Parties .................................................................................................................................... 26
3.1 CDB Group Organizational Structure....................................................................................... 26
3.2 Transfer Pricings...................................................................................................................... 26
3.3 Affiliated Parties .................................................................................................................. 26
3.3.1 Sales Transactions to Affiliates .................................................................................... 26
3.3.2 Receivable Transactions from Affiliates ...................................................................... 27
3.3.3 Debt Transactions to Affiliated Parties ........................................................................ 27
Chapter IV ........................................................................................................................................... 28
Industry Analysis ................................................................................................................................. 28
4.1 Textile and Textile Products Industry in the Global Market .................................................... 28

4.2 Textile Industry and Products in Indonesia ............................................................................. 30
4.3 Business Strategy .................................................................................................................... 30
Chapter V ............................................................................................................................................ 32
Functional Analysis ............................................................................................................................. 32
5.1 Objectives of Functional Analysis ............................................................................................... 32
5.2 Functions performed by CDB .................................................................................................. 32
5.2.1 Procurement ............................................................................................................................. 32
5.2.1 Inventory ...................................................................................................................... 33
5.2.2 Submission of invoices and billing ................................................................................ 33
5.2.3 Installation and After-Sales Service .............................................................................. 33
5.3 Risk Assumptions .................................................................................................................... 33
5.3.1 Market Risk .................................................................................................................. 33
5.3.2 Inventory Risk ..................................................................................................................... 33
5.3.3 Credit Risk .................................................................................................................... 34
5.3.4 Exchange Rate Differences ........................................................................................... 34
5.4 Assets Used ............................................................................................................................. 34
5.5 Summary ................................................................................................................................. 35
Chapter VI ........................................................................................................................................... 40
Requirements for Transfer Pricing ...................................................................................................... 40
6.1 Indonesian Tax Regulations .................................................................................................... 40
6.2 OECD Transfer Price Guidelines .............................................................................................. 42
6.3 Principles of Fairness and prevalence ..................................................................................... 44
Chapter VII .......................................................................................................................................... 45
7.1 Transfer Pricing Method ......................................................................................................... 45
7.1.1 CUP Method (“Comparable Uncontrolled Price Method”) ........................................... 47
7.1.2 RPM Method (“Resale Price Method”) ........................................................................ 48
7.1.3 CPM Method (“Cost Plus Method”).............................................................................. 50
7.1.4 PSM Method (“Profit Split Method”) ........................................................................... 52
7.1.5 TNMM Method (“Transactional Net Margin Method”) ............................................... 53
7.2 Application of TNMM .............................................................................................................. 56
7.2.1 Parties Analyzed (Tested Party) ................................................................................... 56
7.2.2 Selection of Profit Level Indicators ............................................................................... 56
7.2.3 Overview of Financial Statements ................................................................................ 56
7.2.4 Data Sources ................................................................................................................ 57

7.2.5 Multiple Year Data and Weighted Interquartile Average Range ................................. 63
7.2.6 Adjustment of CDB Comparison .................................................................................. 64
7.2.7 Analysis Results ........................................................................................................... 65

LIST OF TABLES
TABLE 1 - DOCUMENT CONTENTS ....................................................................................................................... 9
TABLE 2 - OWNERSHIP PERCENTAGE FOR 2017 ................................................................................................ 10
TABLE 3 - COMPANIES RELATED TO BOOK YEAR AFFILIATE TRANSACTIONS ...................................................... 10
TABLE 4 - SELECTED PROFIT LEVEL INDICATOR.................................................................................................. 12
TABLE 5 - CALCULATION OF TNMM WITH PROFIT LEVEL INDICATOR ................................................................ 13
TABLE 6 - NET COST PLUS CALCULATION .......................................................................................................... 13
TABLE 7 - COMPOSITION OF THE BOARD OF COMMISSIONERS AND DIRECTORS .............................................. 14
TABLE 8 - COMPOSITION OF SHAREHOLDERS AND OWNERSHIP ....................................................................... 14
TABLE 9 - GENERAL DIVISION FUNCTION .......................................................................................................... 15
TABLE 10 - SALES TRANSACTIONS TO AFFILIATES .............................................................................................. 26
TABLE 11 - LIST OF RECEIVABLE TRANSACTIONS FROM AFFILIATES................................................................... 27
TABLE 12 - DEBT TRANSACTIONS TO AFFILIATES ............................................................................................... 27
TABLE 13 - ASSET STRUCTURE CDB ................................................................................................................... 34
TABLE 14 - SUMMARY OF FUNCTIONS, ASSETS AND RISK OF CDB ..................................................................... 35
TABLE 15 - PLI CHOSEN ..................................................................................................................................... 56
TABLE 16 - SUMMARY OF THE 2017 CDB FINANCIAL REPORT ........................................................................... 56
TABLE 17 - US SIC TP CATALYST ........................................................................................................................ 58
TABLE 18 - TYPES OF INDEPENDENCE INDICATORS ........................................................................................... 58
TABLE 19 - TYPES OF FINANCIAL INFORMATION ............................................................................................... 59
TABLE 20 - LIST OF FINAL COMPARATIVE COMPANIES ...................................................................................... 62
TABLE 21 - SUMMARY OF FINANCIAL REPORTS AFTER ADJUSTMENT................................................................ 64
TABLE 22 - ANALYSIS RESULTS .......................................................................................................................... 65
LIST OF FIGURES
FIGURE 1 - CDB ORGANIZATIONAL STRUCTURE ................................................................................................ 17
FIGURE 2 - GENERAL PRODUCTION PROCESS FLOW.......................................................................................... 19
FIGURE 3 - QUALITY CONTROL .......................................................................................................................... 23
FIGURE 4 - CDB GROUP SHAREHOLDERS ........................................................................................................... 26
ATTACHMENT
ATTACHMENT A - SEARCH COMPARISON IN THE ORBIS CATALYST DI TP CATALYST ORBIS ................................ 67
ATTACHMENT B - MANUAL SELECTION............................................................................................................. 68
ATTACHMENT C - COMPANY ELIMINATED DUE TO DIFFERENT BUSINESS PROFILE ........................................... 70
ATTACHMENT D - FINANCIAL INFORMATION OF FINAL COMPARISON COMPANY .......................................... 101

ABBREVIATIONS LIST
Abbreviations Information
CDB PT Cipta Dwi Busana
OECD Organization for Economic Co-operation and Development
DJP Directorate General of Taxes
PER 43 Peraturan DJP No. PER-43/PJ/2010
PER 32 Peraturan DJP No. PER-32/PJ/2011
PER 22 Peraturan DJP N PER-22/PJ/2013
PMK 213 Peraturan Menteri Keuangan No. 213/PMK.03/2016
RPM Resale Price Method
WANCP Weighted Average Net Cost Plus
NCP Net Cost Plus
CUP Comparable Uncontrolled Price Method
CPM Cost Plus Method
PSM Profit Split Method
TNMM Transactional Net Margin Method
PLI Profit Level Indicators
US SIC United States Standard Industrial Classification

Chapter I
Executive Summary
1.1 Document Purpose

The purpose of this document is to make documentation of the analysis of affiliated
transactions (transactions of related parties) between PT. Cipta Dwi Busana (herein
after referred to as "CDB") and related parties that are controlled for the financial year
ending December 31, 2017 based on regulatory the Minister of Finance of the Republic
of Indonesia Number 213 / PMK.03 / 2016 dated December 30, 2016 for applicated the
arm's length principle and general business practices for transactions carried out by
taxpayers with related parties and Transfer Pricing Guidelines for Multinational
Companies and Tax Administration issued by the Organization for Economic
Cooperation and Development (OECD). We are not responsibly for any reviews or
changes agreed or modifications the document to applicable laws and regulations, or
changes to taxation regulations, business practices, and other conditions that affect
TBrights, affiliated parties or comparison company, from the date this document was
issued.
1.2 The Scope of Document

This document describes the selection and implementation of the transfer pricing
methodology that is most suitable for transactions involving the company and related
parties it controls. In preparing this document, we rely on information provided by CDB.
This document will acknowledge that:
The results and recommendations in this report will be kept confidential, for internal
use of CDB and are intended solely for the purpose of describing the application of
principles in transactions that are controlled between CDB and affiliated companies.
The document will not be used for other purposes or distributed to other parties
without our prior written consent. The document can be submitted to the tax authority
if there is a request for the principle of arm's length principle that occurs between
companies.

In carrying out this work, we will rely on information provided from companies,
including from company management and information available from databases and
from the internet.
We believe that our recommendations will reflect a reasonable interpretation of

transfer pricing rules and practices in relevant jurisdictions, up to date of the document,
in which case there is no guarantee that the tax authorities in these jurisdictions can
adopt the same view.
If there are changes in Transfer Pricing regulations in jurisdictions or relevant market

conditions where the company operates, or in business practice, opinions and
recommendations may need to be re-evaluated. Any re-evaluation needs to be agreed
upon in a other agreement.
1.3 Occupation
To test whether the conditions and prices or profits imposed in the controlled
transactions between the CDB and the related parties to which it is controlled are
reasonable in accordance with arm’s length principle, we undertake following
approach:
1. Overall analysis of CDB.
We do the following:
a. Look for information that is publicly available in connection with the industry
where CDB operates;
b. Additional interviews and correspondence with employees on site;
c. Look for information about CDB competitors in the same business field.
2. Try to understand the controlled transactions that we are examining in particular
through examining the five comparative factors of controlled transactions, namely:
characteristics of goods and services; functions, assets, and risks; business contract
or agreement; economic conditions; and business strategy.
a. Visit to the main office;

b. Observation of business activities and meetings with core management personnel
regarding business operations;
c. Compilation of functional analysis questionnaires and completeness lists, as well
as detailed transfer pricing profiles that must be completed by the company;
d. Review responses given in the complete list of functional analysis, and detailed
transfer pricing profiles;
e. Review of financial statements for the year ended December 31, 2017,
information on sales of goods and services, agreements between companies and
third parties, as well as documents and other relevant information.
3. The most appropriate selection transfer pricing method based on application of the
transfer pricing method to achieve the most reliable measure for arm's length
principle against controlled transactions.
4. Evaluate alternative transfer pricing methods that have the potential to be applied
to the transactions covered.
5. Detailing all transactions by CDB to affiliated parties.
6. Identify sources of information from available databases to costs incurred by CDB
to affiliates where comparison for those database are needed by considering their
relative reliability, and determining the main characteristics that must be met by
comparators that are considered to be potential based on relevant factors.
a. Collect and learning CDB data related special relationships with transaction
partners, Nobland and other affiliated parties, namely PT. Gunung Salak Sukabumi;
b. Gather financial information and other relevant information about uncontrolled
prices;
7. Make price adjustments if appropriate or needed.
8. Conduct an economic analysis of CDB services.
9. Discussing our findings with CDB management.
10. Collect additional facts and additional economic analysis based on input received
from management.
11. Issuance of the transfer pricing report for the fiscal year ending in December 31,
2017.

1.4 Document Contents
Based on directives in Regulation of the Minister of Finance of the Republic of Indonesia
Number 213/PMK.03/2016, this local document includes the following elements:
Table 1 - Document Contents
Document Principle References
Executive Details Chapter I
Business Summary Chapter II
Organizational structure Chapter II
Related parties Chapter III
Industry Analysis Chapter IV
Functional Analysis Chapter V
Transfer Pricing Regulations Requirements Chapter VI
Selection of Transfer Pricing Determination Chapter VII
Methods
Details of the Company's Financial Data Attachment
1.5 Group Overview

The company was established on July 15, 2005 based on Notarial Deed No. 14 made by
Sastriany Josoprawiro, SH. The deed of establishment was approved by the Ministry of
Law and Human Rights of the Republic of Indonesia through Decree C-3315 HT.01.01
dated December 13, 2005. Changes have been made several times, most recently with
the notary deed of Arsin Effendy, SH, No. 35 dated September 16, 2016 concerning
changes to the Board of Directors and commissioners of the company. CDB has been
designated as a Bonded Zone and the approval of the Operator of Bonded Zone
concurrently as an Entrepreneur in a Bonded Zone through Decree of the Minister of
Finance No. 00 / KMK.04 / 2006 dated February 20, 2006.
The scope of CDB activities covers textile garment industry where CDB makes orders
based on the criteria the buyer wants. CDB only provides tailor-made or called maklon,
where almost all of the sales transactions are provided to affiliates in this regard are
Nobland International Inc.

The percentage of CDB ownership is as follows :
Table 2 - Ownership Percentage for 2017
Percentage Total
Number Information Number of Shares
of Shares (Rp.)
1 Nobland 19.850.000 99% 194.827.750.000
International Inc
2 Noble Industry 150.000 1% 1.472.250.000
Co Ltd
Total 20.000.000 100% 196.300.000.000
1.6 Controlled Transactions Checked

For fiscal year 2017, afilliated transactions carried out by testing are sales, trade
receivables, other receivable, current liability and temporary loans.
The details of transactions with affiliates are as follows:
Table 3 - Companies Related to Book Year Affiliate Transactions
2017
Type of Type of
Company Total Transaction
No. Transaction Country Company
Name (Rp.) Statement
Relations
1. Sales Service Nobland Korea Companies 270.376.045.660 Sales to affiliated
Manufacture International that are parties
controlled by
the group
2. Trade Nobland The Korea Companies 51.528.034.135 Receivable from

Receivable GAP I that are affiliated parties
Harrison controlled by
Street the group

Type of Type of
Company Total Transaction
No. Transaction Country Company
Name (Rp.) Statement
Relations
3. Temporary PT Gunung Indonesia Companies 40.745.860.001 Other receivable
Accounts Salak that are to affiliated
Receivable Sukabumi controlled by parties
the group
4. Current Nobland Korea Companies 78.674.997 Current Liability

Liability International that are
controlled by
the group
Total
362.728.614.793
1.7 Characteristics of Business
CDB is engaged in the apparel industry whose products are in the form of knitwear for
sale to global and private owners, Nobland International. CDB has a factory located in
Sukabumi, West Java, Indonesia and produces knitwear at the factory. The 6 raw
materials are provided by Nobland, while the design and product specifications are
provided by the buyer. CDB uses subcontractors for laser cut, piping, borders, and
coloring.
1.8 The Most Appropriate Transfer Pricing Method

The Transactional Net Margin Method (TNMM) method or the Transactional Net Profit
Method is chosen as the most appropriate method to evaluate arm's length of
controlled transactions conducted by CDB to other parties, namely transfer pricing
methods that use level indicators an independent transaction profit to determine the
net income of an affiliate transaction business. The selection of the parties being tested
is based on an analysis of the functions that have been made and the reliability of the
data or evidence and the facts obtained at the time of making Local Documents. CDB
has its own unique function in Indonesia so that the affiliate transactions tested are for

transactions carried out by CDB to affiliates, namely sales of manufacturing services,
trade accounts receivable, temporary accounts receivable, and current liability based on
analysis of functions that have been made and reliability of data or evidence or
information and facts obtained in the examination. In general, those who are selected
as tested parties are parties that have less complex functions and do not have unique or
valuable intangible properties.
1.9 Results of Analysis
CDB is a knitwear manufacturing company that sells to global and private owners,
Nobland International. CDB operates in Indonesia where CDB related data or evidence
and facts can be obtained and can be observed accurately and reliably. Therefore,
comparable independent comparison companies can also be identified. Meanwhile,
data or evidence, information as well as facts related to affiliated parties to transactions
are difficult to obtain and observe. Therefore, CDB was selected as the tested party in
this report.
Profit Level Indicators (PLI) is a ratio that measures the relationship between the profits
obtained by CDB on costs incurred. The application of TNMM requires the selection of
the appropriate PLI. The selection of PLI is determined by the type of business activity of
the company and the availability of comparative data.
The following table shows the PLI used.
Table 4 - Selected Profit Level Indicator
Ratio Formula
Net Cost Plus Gross Profit/(Cost of Goods
Sold+Operating Expense)
The benchmarking analysis results, namely the Weighted Average Net Cost Plus for
2013 to 2015 for CDB produced 19 comparable companies and showed data of the
Lower Quartile Net Cost Plus of 1.65% and the Upper Quartile of 10.20% and the
median of 6.42 %. Net Cost Plus for CDB transactions and affiliated parties is 4.50%, so it
can be concluded that the transactions carried out by CDB and affiliated parties are in
accordance with the principle of arm and length principle.

Calculation of TNMM can be seen in the following table:
Table 5 - Calculation of TNMM with Profit Level Indicator
WA NCP NCP NCP NCP

2013-2015 2015 2014 2013
Ta
Number of observations (companies) 19
ble
6- Maximum 21,85% 23,21% 21,17% 20,88%
Net
Upper Quartile 10,20% 12,09% 10,07% 10,27%
Cost
Plus Median 6,42% 6,88% 5,57% 7,21%
Calc
ulat Lower Quartile 1,65% -0,50% 1,18% 3,52%
ion Minimum -5,24% -36,30% -5,03% -2,37%
Actual FY 2017
Calculation of Net Cost Plus
(Thousands Rupiah)
Revenue 270.889.898.467
COGS 213.157.910.950
Gross Profit 57.731.987.517
Gross Margin 21,31%
Operating Expense 46.069.057.761
Operating Profit (Loss) 11.662.929.756
Net Cost Plus 4,50%
Chapter II
Business Overview
2.1 CDB Background
CDB is part of the Nobland International Inc. business group (Group) CDB is engaged in
providing knit clothing manufacturing services. In its business activities, CDB produces
apparel from global textile brands. CDB is located on Jl. Raya Cidahu Km. 2 Ds. Pondokkaso
Tonggoh Kec. Cidahu Kab. Sukabumi 43358.

2.2 CDB
2.2.1 Summary of CDB
CDB was established on July 15, 2005 under the Foreign Investment Law No. 1 year
1967 which has been amended by Law No. 25 year 2007 regarding Foreign Capital
Investment, by Notary Deed No. 14 made by Sastriany Josoprawiro, SH. The Deed of
Establishment has been approved by the Ministry of Justice and Human Rights of the
Republic of Indonesia under Decree C-3315 HT.01.01 dated December 13, 2005. The
CDB has been designated as Bonded Zone and the granting of Bonded Zone Organizer
and Entrepreneur in Bonded Zone has been received from the Minister of Finance
Republic of Indonesia through decree no. 00 / KMK.04 / 2006 on February 20, 2006. Has
been amended several times, most recently by notarial deed Arsin Effendy, SH, No.35
dated September 16, 2016 regarding the change of the Board of Directors and CDB
commissioners.
Composition of the Board of Commissioners and Directors in CDB as for December 31,
2017 are as follows:
Table 7 - Composition of the Board of Commissioners and Directors
Name 2017
Mr. Kwon Ogeun Commissioner

Mr. Park Sung Tai Director
2.2.2 Shareholders
Based on the CDB Audit Financial Report for the period January - December (Fiscal Year
2017), the composition of the shareholders and ownership structure of CDB as at 31
December 2017 is in accordance with the following tables and figures:
Table 8 - Composition of Shareholders and Ownership
No. Company Name Number of Shareholder Number of

Shares (%) Shareholders
1. Nobland International 19,850,000 99% Rp. 194,827,750,000
Inc
2. Noble Industry, Co. 150,000 1% Rp. 1,472,250,000
Ltd.
Total 20,000,000 100% Rp. 196,300,000,000
2.2.3 CDB Organizational Structure

In general, CDB was established in 2005 as a knitwear industry. Functions &
Organizational Structure of the CDB can be seen in the tables and charts below:
Table 9 - General Division Function
Division Function
Director Take full responsibility in carrying out duties for the benefit
of the company in accordance with applicable regulations
Quality Assurance Ensure that all quality standards are met by each component
(QA) of the product or service provided by the company to
provide quality assurance according to the standards
provided by the company
Production Responsible for all production activities starting from
mechanic, maintenance, planning, sample making, cutting,
sewing, finishing until the goods produced enter the
warehouse before being sent to the buyer
Compliance Fulfill the top management's wishes so that good
governance can be implemented perfectly
HRD Take full responsibility in the human resources of a company
starting from the preparation of recruiting new employees
to take care of his employment contract
Division Function
Official Provide considerations and proposals from the legal aspects
of the problems faced by the company and carry out the
tasks of managing licensing documents and making
employment contracts
Accounting Record, check, and report on all transactions related to
office finances
Exim Responsible for monitoring the preparation of the Export
Import document, checking the Export Import document

that is adjusted to the LC, monitoring the delivery and
receipt schedule
Purchasing Responsible for the procurement of goods or services
needed by the company
IT Responsible for caring for software / hardware / computers
in the company, making repairs if something is damaged,
ensuring that all hardware and computers function
optimally, evaluating and improving the performance of IT
systems, etc
General Affair Responsible for maintaining good relations with the
(GA) environment around the company, the existence and
condition of company assets, maintaining office facilities,
conducting the process of procuring office facilities and
equipment, arranging official vehicles, arranging insurance,
analyzing the budget requirements for procurement and
maintenance of all office facilities
Production Responsible for all production activities starting from
mechanic, maintenance, planning, sample making, cutting,
sewing, finishing until the goods produced enter the
warehouse before being sent to the buyer

FIgure 1 - CDB Organizational Structure

2.2.4 Production Process of CDB
CDB is carrying out its production process at a factory located in Sukabumi,
West Java, Indonesia. The raw material is provided by Nobland, while design
and product specifications are provided by the buyer. CDB factories have
land and building area of 83,718m2 and 54,443m2. The production capacity
that can be produced by the factory is equal to 1,076,701 pcs. The amount
of capacity is supported by ± 3,800 workers and the number of sewing lines
of 52 lines and 36 machine lines. The production process can be seen in the
following chart:
The majority of customers from CDB who use CDB production are brands
such as Target (30.34%), Old Navy (48.31%), SEARS as much (3.4%),
Forever 21 (1.12%), Wallmart (1.12%), and GAP (15.73%).
Local Document PT Cipta Dwi Busana Fiscal Year 2017

Page 18
FIgure 2 - General Production Process Flow

Page 19
The following details of the general business flow of CDB:
1. Preparation of raw materials or fabrics, accessories, make clothes
design as desired by the buyer, enter the design that is in accordance
with the design and size desired by the buyer into a computerized
system called NTIS System.
2. Pre-Production Meeting: all division heads meet with buyers to discuss
the production process that will be carried out from beginning to end
to minimize the occurrence of errors in each division.
3. Pilot Run: before mass production is carried out, samples that have
been approved by the buyer are tested to check production
techniques, quality requirements, and engine preparation.
4. Cutting: the process of cutting fabric and checking the quality of clothing
components by Quality Control to sort pieces, numbering pieces and
bundling.
5. Sewing: the process of combining pieces or components of clothing into
whole clothes and checking the quality of clothing by Quality Control to
sort the results of pieces of clothing that have been combined in
accordance with the desired results of the buyer.
6. Washing : the washing process is carried out to remove stains and fade
after passing the cutting and sewing process.
7. Ironing : the ironing process uses a steam iron to remove tangles,
blemishes and provide a neater effect. The ironing division receives
clothes from line sewing (sewing) that have been carried out washing,
and have been checked by quality in line sewing control.
8. Finishing : ensure that the products that have been produced are in a
good and appropriate condition in terms of quality, appearance and
conformity with the packing specifications specified by the buyer.
9. Needle Detector : insert garment products into a tool to scan for
unwanted metals or components that endanger the customer for
example; sewing needle fracture.

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10. Packing : the process of packing clothes in polybags, also giving
accessories, ribbons, flowers, solations, etc., then grouped according to
size, design and color.
• Pre-Final : taken every 10%, 50% and 75% after the garment
enters the packing, AQL (Acceptable Quality Level) from pre-final
inspection adapts to the AQL requested by the buyer, at present
most buyers use AQL 1.5.Pre-Final 10% : Performed after Qty
packing reaches 10% of Qty order.
• Pre-Final 50% : Performed after Qty packing reaches 50% of Qty
order.
• Pre-Final 75% / 100% : Performed after Qty packing reaches 50%
of Qty order.
Example of reading that table is as follows, if the Qty orders 3000 pcs, it
means that the Quantity is in the range 3201-10000, so the amount to be
taken for inspection is 200 pcs. And if 200 pcs are found 8 pcs or more major
defects, then Qty 3200 pcs are considered reject and reworked.
2.2.4.1 Quality Control Procedure in CDB

To fulfill high quality products, besides having to comply with the standards
requested by the buyer, on the other side is buyer satisfaction. Buyer

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satisfaction is a concern of product quality, because as long as production
process and under controlled process so long as the production is running,
the product is in accordance with what the buyer wants or wishes.
In production process for garment or clothing production, every stage of the
process is carried out quality control from the Quality Control. Technically,
quality control in the CDB consists of the following parts:

Page 22
FIgure 3 - Quality Control
a. Quality Control (QC) Raw Materials and Accessories in the Warehouse

Quality control is carried out to find out the quality of raw materials
that will be processed in the cutting section and check the quality of

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accessories. The purpose of quality control in raw materials, especially
fabrics, is to determine the quality of materials that are within the
tolerance limits of buyers or buyers, before being processed into mass
products.
b. Quality Control (QC) on Cutting
Quality control in the cutting process includes; inspection of fabric
mat, inspection of marker patterns, inspection of cut panels, and
inspection of panel changes.
c. Quality Control (QC) on Sewing
Quality control in the sewing process includes; in-line inspection and
end-line inspection
d. Quality Control (QC) on Washing
Quality control in this process includes inspection of garment washing
e. Quality Control (QC) on Finishing
Quality control in this process includes; ironing, measurement
inspection, finishing inspection, and needle inspection
f. Quality Control (QC) on Packing
Quality control in the Packing process includes; Packing Inspection,
Pre-Final Inspection and Final Inspection
2.2.5 CDB Product Description

CDB is a manufacturing service provider in connection with the production
of knitwear where the main raw materials have been prepared by Nobland
International Inc. and the design and product specifications have been
provided by buyers. Nobland International Inc. supplies the products to
several global brand owners, including GAP, Target, Old Navy, Sears, H & M,
American Eagle Outfitters. The results of CDB production consist of jackets,
dresses and so on.

Page 24
2.2.6 Conclusion
Based on data and information as intended above, CDB operates in
manufacturing sales knitwear for global brand owners such as GAP, Target,
Old Navy, SEARS, H & M, American Eagle Outfitters. Through a structured
production process and quality control in each division, making the products
produced are as expected by the buyer, thus the company must maintain
the production system that has been carried out in accordance with the
standard operating procedures, because in the future products with global
brands that will become more famous, CDB is also growing in the world of
global brand knitwear manufacturing.

Page 25
Chapter III
Related Parties
3.1 CDB Group Organizational Structure
The details of CDB's share ownership are 99% owned by Nobland International
Incorporation and 1% owned by Noble Industry. Other share ownership affiliated
companies can be seen in the table below :
FIgure 4 - CDB Group Shareholders
Korea
Noble
Kim Ki-Hong
0,25% 1% Industry 23,92%
53,02%
Korea
HWI
Nobland International
4% Inc
99,75% 99% 100% 100% 100% 100% 100%
Indonesia Vietnam Amerika China

Nobland
Cipta Dwi Gunung Salak Nobland Nobland Nobland IG Nobland New
International
Busana Sukabumi Vietnam VINA Vietnam York
Shanghai
3.2 Transfer Pricings

In its business, CDB carries out transactions with affiliates such as, sales, accounts
receivable, other receivables, short-term debt, and temporary loans.
3.3 Affiliated Parties

3.3.1 Sales Transactions to Affiliates
Table 10 - Sales Transactions to Affiliates
Transaction
No Company name Country Value
Type
1 Nobland International Inc Korea 270,376,045,660 Sales
Total 270,376,045,660

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This sales transaction is the provision of manufacturing services provided by CDB
to Nobland International Inc. Provision of manufacturing services to special foreign
relations parties is carried out in USD currency and FOB shipping terms with a
credit period of 30 days after delivery. On the other hand, sales to third parties
apply CnF shipping conditions with an upfront credit period of up to several days
after delivery.
3.3.2 Receivable Transactions from Affiliates

Table 11 - List of Receivable Transactions from Affiliates
Transaction
No Company name Country Value
Type
1 Nobland International Inc Korea 51.528.034.135 Accounts
receivable
2 PT Gunung Salak Indonesia 40.745.860.001 Accounts
Sukabumi receivable
Total 92.273.894.136
Receivables with a value of Rp. 51,528,034,135 is a transaction of receivables from

affiliates, in the form of sales to Nobland International Inc., while the value of Rp.
40,745,860,001 is a non-agreement loan transaction to PT Gunung Salak Sukabumi
with an interest rate of 4% every year, paid every 3 months, without collateral and
due on December 15, 2016 with a value of USD 1,024,339.93.
3.3.3 Debt Transactions to Affiliated Parties

Table 12 - Debt Transactions to Affiliates
No Company name Country Value Transaction

Type
1 Nobland International Inc Korea 78.674.997 Debt
Total
Value of Rp. 78,674,997 is a debt for accrued claims to Nobland International Inc.

Page 27
Chapter IV
Industry Analysis
4.1 Textile and Textile Products Industry in the Global Market
In apparel market, the market values including domestic production plus imports
are reduced by exports, all of which are valued at producer prices. The global
clothing market is expected to reach $ 1,004.6 billion by 2021, increasing by 19.2%
since 2016. The annual market growth rate in the 2015-20 period is estimated at
3.6%.
Global apparel manufacturers and apparel companies are the Adidas group,
Buckle Inc., Columbia sportswear company, Gap Inc., JC Penney Company Inc.,
Kohl's Corporation, Liz Clairborne Inc., Macy's Inc., Nike Inc., Lenzing group, and
many more.
The global textile garment market value reached $ 667.5 billion in 2015 (around
83.1% were fabrics and 16.9% were yarn), up 1.5% from the previous year. The
global textile factory market is estimated to reach $ 842.6 billion in 2020, an

Page 28
increase of 26.2% since 2015. The annual market growth rate in the 2015-2020
period is estimated at 4.8%.

Page 29
4.2 Textile Industry and Products in Indonesiai1
Exports of Indonesian textile & garment products (T & G) to the United States
(US) fluctuate, even from 2012 - 2017 the value of their exports continued to
decline. While Indonesian Cotton Imports from the US continue to increase.
Market Share Indonesian T & G products in the US market since 2011 - 2016
continued to decline.
In 2017, the export value of Indonesian textiles and textile products grew by 6%
from US $ 11.83 billion in 2016 to US $ 12.54 billion, this achievement occurred
due to high demand especially to Asean countries, Japan, China and America
Union. Investment in textile and textile products companies also rose 68% from
Rp. 7.62 trillion in 2016 to Rp. 12.81 trillion. Investors are still dominated by
domestic investors (Domestic Direct Investment) at 61.4% compared to Foreign
Direct Investment (FDI) which is only 38.6%.
Indonesia's potential for involvement in producing world-renowned products will

continue to grow. Based on data obtained from Members of the Indonesian
Textile Association (API), around 150 to 200 world brands are produced in
Indonesia such as Zara, Adidas, Nike, The North Face, Amer Group, Salomon,
Arcteryx, Calvin Klein, and H & M.
Indonesian garment and garment manufacturers include PT Busana Prima Global,

PT Rapico Busana Permata Indah, PT Pan Brothers Tbk and other home producers
located in Java.
4.3 Business Strategy

The management activities of the company deal with the basis of the selection of
business lines, the selection of organizational structures, determining quality
standards and assisting the development of new products, including maintaining
1
Source: Various government publication.
Page 30
all existing products in accordance with standard operating procedures for the
purpose of cost efficiency and effectiveness of labor to increase operating profit,
review budgets and variance, analyze market strategies and respond to
competitors and predict markets.
The overall strategy of the company is determined locally by CDB. However,

decisions taken by CDB management must be approved by Nobland Group. The
shareholders are involved in determining the sales budget and CDB targets

Page 31
Chapter V
Functional Analysis
5.1 Objectives of Functional Analysis

Functional analysis provides a factual foundation for establishing transfer pricing
methodologies that are in accordance with the principle of fairness and
prevalence (arm’s length). It aims to regulate facts about the company in terms
of functions performed, assets used (both tangible or intangible), and assumed
risks to identify how these characteristics are shared between the entities
involved in the transaction being reviewed.
The purpose of the following functional analysis is to provide an understanding
of the functions performed, assumed risks, and assets used by the Company and
affiliated parties in the context of their affiliate transactions.
5.2 Functions performed by CDB
5.2.1 Procurement
The procurement function is the process by which a company buy raw materials
or products which will then be sold to end consumers. The purpose of this
function is to get the highest quality products and the best prices, which then
allows for higher margins. These activities include the identification and
qualifications of new and existing suppliers, negotiating purchase requirements,
and establishing quality standards for purchasing raw materials.
The raw material is bought by Nobland to third parties. In this case, Nobland
determines plans for purchasing raw materials, quality of raw materials,
quantity of raw materials, and negotiations with suppliers. Raw materials are
imported directly from suppliers to the Company. For this reason, CDB does not
have rights to the raw materials provided by Nobland. However, CDB was given
the authority to buy supporting materials to domestic suppliers with approval
from Nobland.

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5.2.1 Inventory
Inventory is material in the form of raw materials, work in process, or finished
goods stored in a place or warehouse where the goods are waiting to be
processed or produced further.
Raw materials that have been purchased by Nobland stored in the CDB-owned
warehouse and the warehouse are responsible for controlling the raw materials
including updating inventory in the NTIS system (Nobland Total Information
System). Nobland always adds ± 2% of the total raw materials purchased as
reserves if there are obsolete raw materials.
In managing inventory, fire and loss are at risk. However, the company has
implemented All Risk Insurance as a step taken to reduce these risks.
5.2.2 Submission of invoices and billing

Submission and invoice collection is carried out by CDB itself, so CDB has an
obligation to monitor its receivables and collection.
5.2.3 Installation and After-Sales Service

CDB does not carry out after-sales services. So that you will bear the risk or
cost after the sale is the buyer.
5.3 Risk Assumptions

5.3.1 Market Risk
Market risks that arise are due to a decrease in demand from buyers. The effect
of the global economy greatly influences the demand of buyers, when global
economic conditions related to apparel products increase or decrease, it will
affect CDB market risk.
5.3.2 Inventory Risk

Inventory risk that arises is the obsolescence of inventory when the production
has not been sold until a certain period.

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5.3.3 Credit Risk
Credit risk arises when CDB makes sales by credit. From this transaction none of
the parties did not pay their obligations to CDB, so the risks arising from credit
sales transactions were very small in the CDB.
5.3.4 Exchange Rate Differences
The risk of foreign exchange rates related to CDB sales is abroad and in foreign
currencies. Foreign exchange risk in the CDB business is high because there is no
hedging system.
5.4 Assets Used

The purpose of functional analysis is to identify the owner of tangible and
intangible assets. Thus, legal ownership and economic ownership must be
distinguished. Legal ownership must be related to ownership which is usually
documented in the public register, etc. Economic ownership is related to the
question of whether and to what extent the entity has acquired ownership by
financing certain activities in relation to intangible assets or more importantly,
intangible.
The CDB asset structure can be seen in the table below:
Table 13 - Asset Structure CDB
Description 2017 2016

Fixed assets
Land 11.915.418.850 11.915.418.850
Building 95.971.515.369 89.283.800.542
Machine 63.773.881.953 85.592.593.466
Electrical installation 7.337.648.451 7.098.186.751
Vehicle 3.807.753.842 3.807.753.842
Office and Factory Equipment 25.272.554.997 24.573.862.321
Accumulated Depreciation
Land

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Building 33.222.732.462 35.664.154.915
Machine 37.113.168.593 43.996.227.540
Electrical installation 4.650.191.113 5.085.201.685
Vehicle 2.016.023.604 2.425.301.375
Office and Factory Equipment 23.140.265.137 22.773.259.882
Net book value 107.936.392.552 112.327.470.376
Fixed assets that are no longer used or sold, the acquisition cost and the
accumulated depreciation are removed from the fixed assets group and the
resulting profits and losses are recognized in the income statement.
Intangible assets owned by CDB are in the form of developed patterns, technical
skills and production used in the manufacturing process. CDB does not have non-
routine intangible assets such as product development, design, know-how,
patents, trademarks, brands or overseas customer networks. This intangible
asset is owned by Nobland and CDB utilizes Nobland's product, network and
customer relationship development.
5.5 Summary
Based on the functional analysis mentioned above, it is noted that CDB has a
high market risk, because:
Table 14 - Summary of Functions, Assets and Risk of CDB
Affiliate Third
No. Functions, Assets, and Risks CDB
Parties Parties
I. FUNCTION
A. Purchase of raw materials
1. Supplier selection xx xx -
2. Manage scheduling xxx - -
3. Supervision of the quality of xxx - -
merchandise

Page 35
Affiliate Third
Parties Parties
4. Negotiate the purchase price xx xx -
5. Owner of merchandise xxx - -
B. Packaging, warehousing and
logistics
1. Packing xxx - -
2. The party overseeing xxx - -
merchandise inventory
3. The party that keeps the xxx - -
merchandise inventory
C. Quality Control
1. Test product quality xx xx -
2. Determine standard xx xx -
operating procedures for
quality control
D. Marketing, advertising and
promotion
1. Market analysis x xxx -
2. Market research x xxx -
3. Market penetration - xxx -
4. Determine the market - xxx -
strategy
5. Performing exhibition - xxx -
activities
6. Serve customers xxx - -
7. Advertising and promotion x x -
E. Sales
1. The party that determines the xxx - -
selling price

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Affiliate Third
Parties Parties
2. Receive orders from xxx - -
customers
3. Sales Administration xxx - -
4. Sales personnel xxx - -
5. Signing of sales contract xxx - -
6. Product distribution / xxx - -
shipping
7. Insurer on transportation xxx - -
costs
8. The parties that issued the xxx- - -
sales invoice
9. Billing Parties xxx - -
F. Installation and after sales service

1. After sales service - - -
2. Product warranty and - - -
guarantor of warranty costs
G. Administration and other
functions
1. General and administrative xxx - -
2. Human Resources xxx - -
3. Finance xxx - -
4. Legal xxx - -
II. ASSET
A. Intangible assets
1. Owner of the patent for the - - xxx
product

Page 37
Affiliate Third
Parties Parties
2. Trademark owner - - xxx
3. The parties that develops - - xxx
intangible assets (e.g. brands)
4. Have know-how related to - - xxx
making software
B. Tangible assets
1. Land owner xxx - -
2. Shop and building owners xxx - -
3. Inventory owner xxx - -
4. warehouseman xxx - -
5. Owner of sales support xxx - -
facilities
III. RISK
1. Parties who bear market risk - xxx X
2. The parties who bears the risk xxx - -
of obsolete inventory
3. Parties who bear the risk of xxx - -
product damage and
warranty
4. The parties that bears the risk xxx - -
of uncollectible credit /
receivables
5. The parties that bears the risk xxx - -
of fluctuations and exchange
rates / foreign exchange
The full description of the top marks is as follows:

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xxx : perform functions, assets, and risks with high levels / weights;
xx : perform functions, assets, and risks with moderate levels / weights;
x : perform functions, assets, and risks with low levels / weights;
- : does not carry out functions, assets, and risks at all.

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Chapter VI
Requirements for Transfer Pricing
6.1 Indonesian Tax Regulations

Indonesia has the basic provisions for transfer prices as follows:
Article 18 of the income tax law
Director General of Taxes is authorized to reallocate income and deductions
between related parties and to characterize debt as equity for the purposes of the
computation of taxable income to assure that the transaction are those which
would have been made between independent parties using price comparison
method between independent parties, resale price method, cost-plus method, or
other methods.
The term “related Taxpayer” as referred to in paragraph (3) to paragraph (3d),
paragraph (1) subparagraph (f) of Article 9, and paragraph (1) of Article 10 means:
a. A Taxpayer who owns directly or indirectly at least 25% of equity of other
Taxpayers; a relationship between Taxpayer through ownership of at least 25% of
equity of two or more Taxpayer, as well as relationship between two or more
Taxpayer concerned; b. A Taxpayer who controls other Taxpayer; or two or more
Taxpayers are directly or indirectly under the same control; c. a family relationship
either through blood or through marriage within one degree of direct or indirect
lineage.
Minister of Finance Regulation No. 213/PMK.03/2016
(1) In Article 2 the Transfer Pricing Document consists of :
a. Master Document
b. Local File
c. Country by country report
(2) Taxpayers who carry out Affiliated Transactions with :
a. Circulation of the previous fiscal year gross value in one Tax Year more
than Rp. 50,000,000,000.00 (fifty billion rupiahs);

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b. The value of the Affiliated Transaction of the previous Tax Year in one Tax
Year:
1. More than Rp. 20,000,000,000.00 (twenty billion rupiahs) for tangible
goods transactions; or
2. More than Rp. 5,000,000,000.00 (five billion rupiah) for each service
provider, interest payments, utilization of intangible goods, or other
Affiliated Transactions, or;
c. Affiliates residing in a country or jurisdiction with a Income Tax rate lower
than the Income Tax rate as referred to in Article 17 of Act Number 7 of
1983 concerning Income Tax as amended several times, the latest by Law
Number 36 of 2008 concerning Amendment The fourth Law Number 7 of
1983 concerning Income Tax, is obliged to hold and store Transfer Price
Determination Documents as referred to in paragraph (1) letters a and b as
part of the obligation to save other documents as referred to in the
provisions of legislation in the field of taxation.
(3) Taxpayers who are Parent Entities of a Business Group that have consolidated
gross circulation in the related Tax Year of at least Rp. 11,000,000,000,000.00
(eleven trillion rupiahs), must carry out and store Transfer Price
Determination Documents as referred to in paragraph (1) letter a, letter b,
and letter c as part of the obligation to save other documents as referred to in
statutory regulations taxation laws.
(4) In the event that a domestic Taxpayer domiciled as a member of a Business

Group and a parent entity of a Business Group are subject to foreign tax, a
domestic Taxpayer must submit a report per country as referred to in
paragraph (1) letter c throughout the country or jurisdiction of the place The
Parent Company is domiciled:
a. Does not require the submission of state reports;

Page 41
b. Has no agreement with the Government of Indonesia regarding
the exchange of tax information; or
c. Having an agreement with the Government of Indonesia regarding
the exchange of tax information, but reports per country cannot
be obtained by the Indonesian government from these countries
or jurisdictions.
(5) The limit of gross circulation value and the value of Affiliate Transactions as
referred to in Paragraph (2) shall be calculated by annualization in the case of
the Tax Year obtaining gross circulation and / or conducting Affiliated
Transactions covering a period of less than 12 (twelve) months.
Transfer Price Determination Documents as referred to in Article 2 Paragraph
(1) letters a and b, must be conducted based on data and information
available at the time of the Affiliated Transaction.
In Article 4 paragraph (1) Transfer Pricing Documents as referred to in Article
2 Paragraph (1) letters a and b, must be available at the latest 4 (four) months
after the end of the Tax Year. The Transfer Price Determination Document as
referred to in Paragraph (1) must be accompanied by a statement regarding
the availability of the Transfer Pricing Document signed by the party providing
the Transfer Price Determination Document.
6.2 OECD Transfer Price Guidelines

Transfer pricing guidelines have been used as a basis for many national transfer
pricing regulatory frameworks. The OECD Guidelines stipulate that the standard
length and arm must be used to set prices between related companies.
References are made to Chapter I, Paragraph 1 Article 9 of the OECD Model Tax
Convention, which states that :
” If conditions are made or enforced between two related companies in their
commercial or financial relationships that are different from those made between
independent companies, then every profit will be, but for these conditions, one

Page 42
company has arisen, but for the reason that condition, has not been counted, can
be included in the company's profits and taxed accordingly”.
To comply with the transfer pricing guidelines listed in the OECD guidelines,
taxpayers must use the appropriate transfer pricing method to establish and test
transactions between companies and related parties. Arm's length is applied by
companies that are independent of each other based on "economic
characteristics. This is comparable if:
- There is no difference between controlled and uncontrolled transactions
- Differences that exist do not materially affect the conditions being
examined; or
- Differences that exist do not materially affect the conditions being
examined; or
The OECD has established a method for setting an arm's length for inter-company
transactions with related parties, which are categorized into two groups:
• Traditional Methods: (Price Comparison Method between Independent
Parties or Comparable Uncontrolled Price, Resale Price Method / Resale
Price, and Cost-Plus or Cost Plus Method)
• Other Methods or Transactional Benefits: (Profit Split / Profit Split
Method and Transactional Net Margin Method)
For these five methods, the OECD divides the five pricing methods into two parts,
namely the traditional method and the transactional profit method.
Traditional methods, namely the first three methods are traditional methods
whose approach is based on transactions, while the transactional profit method is
based on profit.
There is no one method that is appropriate in every situation and for the
application of certain methods. In addition, the principle of reason and practice
(arm's length principle) does not require the application of more than one
method. The aim is to choose a method that tends to give the best estimate of the
price of arm's length. However, for difficult cases where there is no definite

Page 43
method, a flexible approach will allow evidence from various methods to be used
together, to reach conclusions that are consistent with the satisfying arm's length
principle from a practical point of view taking into account the facts and
circumstances of the case , the combined evidence available, and the relative
reliability of the various methods under consideration.
6.3 Principles of Fairness and prevalence
The principle of fairness and prevalence (arm’s length), which is an international

standard for OECD member countries, provides a balance of extensive tax
treatment for related companies and independent companies. Countries that
follow transfer pricing guidelines have emphasized the use of standard arm's
length to evaluate the nature of transactions between companies. The
authoritative statement of the arm's length principle is found in paragraph 1 of
Article 9 and the Tax Convention of the OECD Model Article 9 states:
“In a situation where between the two companies referred to in their trade
relations or their financial relationships are held or applied conditions that deviate
from those that normally apply between companies that are totally independent
of each other, then any profit that should be received by one company if the
terms these conditions do not exist, but they are not accepted because of the
conditions, can be added to the company's profits and taxed.
”Therefore, the principle of reasonableness and prevalence (arm’s length) requires
that taxable income be determined as a sufficient amount to be expected if the
parties interact with each other.

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Chapter VII
Selection of Transfer Pricing Methods
7.1 Transfer Pricing Method

In Article 18 paragraph (3) of the Income Tax Law and its explanation, several
methods have been mentioned which can be used to determine the amount of
income and / or costs in accordance with the fairness and prevalence of
businesses that are not affected by special relationships. This is in line with what is
recognized by the Organization for Economic Cooperation and Development
(OECD) that in the transfer pricing analysis five methods can be used similar to
those mentioned in Article 18 paragraph (3) of the Income Tax Law along with the
explanation. These methods are:
a. The price comparison method is a comparable uncontrolled method,
which is a method that compares the price of an item or service that
occurs in an affiliate transaction with an independent transaction;
b. The method of resale price (resale price method), which is a method
that compares the gross profit earned from affiliate transactions (for
products purchased from affiliates, then sold to independent parties),
with gross profit earned from independent transactions;
c. Cost-plus method, a method that compares the mark-up of costs in an
affiliate transaction with a mark-up on fees charged in an independent
transaction;
d. Profit split method, which is a method that seeks to measure the
fairness of a compensation (in this case profit) received by the company
for its contribution in a group of multinational companies;
e. Transactional net margin method, which is a method that compares the
level of operating profit earned through an affiliate transaction, with
operating profit obtained through an independent transaction.
The OECD divides the five pricing methods into two parts, namely traditional
transaction methods and transactional profit methods. The first three methods

Page 45
are traditional transaction methods where the approach is transaction-based.
While the last two methods referred to are transactional profit methods where
the approach is based on profit.
In 2010, the OECD updated the method of selecting the transfer pricing method
from hierarchy to be the most appropriate method. This was also adopted by
Indonesia with changes to the regulations concerning the application of the
principle of fairness and business prevalence, namely PER-43 / PJ / 2010 to PER-
32 / PJ / 2011 where the determination of hierarchical pricing methods was
changed following changes made by the OECD.
The changes were made with the consideration that in practice, the application
of traditional methods (CUP, RPM, CPM) is very difficult to do, especially because
the ideal and reliable comparison needed for the application of the three
methods is very difficult to find, besides the use of profit-based methods is
increasingly done especially with the availability of commercial databases.
In determining the most suitable transfer pricing method, Article 11 paragraph

(8) PER-32 / PJ / 2011 requires to pay attention to the following matters:
a. The advantages and disadvantages of each method;
b. Conformity of the method of transfer pricing with the nature of
transactions between parties that have special relationships, which are
determined based on functional analysis;
c. Availability of reliable information (in connection with transactions
between parties that have no special relationship) to apply the chosen
method and / or other methods;
d. The level of comparability between party transactions that have a
special relationship with transactions between parties that have no
special relationship, including the reliability of adjustments made to
eliminate the material influence of the differences that exist.

Page 46
7.1.1 CUP Method (“Comparable Uncontrolled Price Method”)
Based on Article 11 paragraph (3) PER-32 / PJ / 2011, the CUP method is a
method of determining transfer prices conducted by comparing prices in
transactions conducted between parties that have a special relationship with the
price of goods or services in transactions conducted between parties parties who
do not have special relations in comparable conditions or conditions.
Among the existing transfer pricing methods, the CUP method is considered the
most appropriate and reliable method of conducting a fair price test. The
approach in the CUP method is the most appropriate and direct approach in
proving that the price applied in an affiliate transaction is reasonable. This is
because the analysis is carried out at the level of the selling price and the
purchase price.
As it is known that there are two data sources that can be used in conducting a
comparison search for the CUP method application. The first internal
comparative data is obtained only when the company carries out transactions
with affiliated parties and also with independent parties in comparable
conditions. The use of internal comparative data in the CUP method will provide
very accurate results if there are no differences that materially can affect the
price of transactions made to affiliated parties or to independent parties.
Second, external comparative data originating from transactions carried out by

third parties without involving the parties being tested. The application of the
CUP method by using external comparison data is done by comparing the prices
of affiliated transactions with the prices of transactions conducted by
independent parties with other independent parties in conditions comparable to
the affiliate transactions analyzed.

Page 47
Based on Article 11 paragraph (9) PER-32 / PJ / 2011, the right conditions in
implementing the CUP method include:
a. The goods or services transacted have identical characteristics in
comparable conditions; or
b. Conditions of transactions between parties that do not have identical
special relationships or have a high level of comparability or accurate
adjustments can be made to eliminate the effect of differences in
conditions that arise.
The CUP method really requires a high level of comparability between affiliated
transactions tested with independent transactions that become comparators. Factors,
among others, the provisions in the contract or agreement, the characteristics of
goods or services, and economic conditions must have a high level of comparability
between the two transactions. If there are differences in these factors, reliable
adjustments must be made in order to be comparable, if it cannot be adjusted, it will
greatly affect the reliability in applying the CUP method.
The CUP method can be theoretically applied to the agreements of parties related to
extensive inter-country transactions, including royalties, loans, services and the price
of tangible goods. However, the application of the CUP method is practically very
limited, unless there are certain commodity transactions or when comparable internal
comparators are available.
Based on a review of the facts and circumstances of affiliate transactions and

independent transactions conducted by CDB, we identify that each of those
transactions cannot be compared using the CUP method.
7.1.2 RPM Method (“Resale Price Method”)

Based on Article 11 paragraph (4) PER-32 / PJ / 2011, the RPM method is a
method of transfer pricing conducted by comparing prices in a product

Page 48
transaction between parties that have a special relationship with the resale price
of the product after deducting profits fair value, which reflects the function,
assets and risks, for the resale of the product to another party that has no special
relationship or the resale of the product carried out in a reasonable condition.
The RPM method is usually used by taxpayers engaged in resellers.
The right transaction scheme to implement this method is if the manufacturing

company sells its products to affiliates who carry out the distribution or
marketing function. Then, the product is resold to an independent party without
first adding substantial value to the product.

applying the RPM method include:
a. A high level of comparability between transactions between
taxpayers that have a special relationship with transactions between
taxpayers that have no special relationship, especially the level of
comparability based on the analysis of functions, even though the
goods or services that are traded are different; and
b. The reseller (reseller) does not provide significant added value for the
goods or services being traded.
In the RPM method, the level or complexity of distribution activities can

significantly affect the profits obtained by the distributor. Distributors who carry
out higher levels of commercial activity will have a higher expectation of profit
rates. However, it should be noted that the level of this activity must be
supported by relevant documentation that the activity was actually carried out.
In addition, the RPM method is highly dependent on the consistency of

accounting practices between parties tested by comparison. This is because the
RPM method tests the gross profit level so that differences in accounting

Page 49
practices can affect the amount of gross profit compared. In order to be
comparable, the effects arising from differences in accounting practices must be
reliably eliminated.
In this report, the RPM method cannot be used because of the limited
comparative information that can be used as a comparison. The internal
comparator or database used in comparison searches for this document does not
provide detailed data on gross profit levels, making it difficult to make
adjustments to increase the comparability between the comparison with the party
being tested. For this reason, it can be concluded that the RPM method cannot be
applied reliably in this document.
7.1.3 CPM Method (“Cost Plus Method”)

Based on Article 11 paragraph (5) PER-32 / PJ / 2011, the CPM method is a
method of transfer pricing conducted by adding the level of fair gross profit
obtained by the same company from transactions with parties that have no
special relationship or reasonable gross profit rate obtained by another company
from a comparable transaction with a party that has no special relationship to
the cost of goods sold which is in accordance with the principle of fairness and
prevalence of the business.
CPM method is generally used when analyzing long-term sale and purchase
agreements, intermediate goods sales, maklon service activities and contract
manufacturing, R & D contracts, and so on. The most appropriate application of
the CPM method is for simple manufacturers, without complex activities, so that
costs and benefits can be easily estimated.

applying the CPM method include:
a. Semi-finished goods are sold to parties that have special
relationships;

Page 50
b. There are contracts / agreements for use of joint facilities or long-
term buy and supply agreements between parties that have a special
relationship; or
c. The form of transaction is the provision of services.
Like the RPM method, the CPM method also uses a ratio of earnings to the level of
gross profit. From an economic point of view, the gross profit obtained by the
manufacturer is compensation for the efficient allocation of the resources owned,
the functions carried out, the risks borne, and the value of the assets it uses in
production.
Similar to the application of the RPM method, the main emphasis on the CPM
method lies in the similarity of functions, assets and risks associated with the
activities of distributors with comparative transactions. Although the products
transacted are different, the CPM method can be applied as long as the products
are still in the same group. Nonetheless, the OECD Transfer Pricing Guidelines also
state that the further the difference in products being compared indicates the
different functions performed. Therefore, the use of broad product criteria in
comparison searches will cause a decrease in the reliability of the analysis results
from the application of this method.
In addition, similar to the application of the RPM method, the CPM method also
requires consistency of accounting practices between parties tested by
comparison. If there are differences in consistency practices, reliable adjustments
need to be made to eliminate these differences. This is because these differences
can greatly affect the level of profits generated by each transaction.
In this report, the CPM method cannot be applied because information is limited
to being used as a comparison. The lack of detailed information about the cost
structure at the level of gross profit from the comparison results in reliable

Page 51
adjustments to increase comparability that cannot be done. Therefore, it can be
concluded that the CPM method cannot be applied reliably in this Report.
7.1.4 PSM Method (“Profit Split Method”)

Based on Article 11 paragraph (6) PER-32 / PJ / 2011, the method of determining
transactional profit-based transfer prices is carried out by identifying joint profits
on affiliated transactions that will be shared by parties that have no such special
relationship using an acceptable basis economically which provides an estimate
of the profit sharing that will occur and will be reflected in agreements between
parties that have no special relationship, using the Contribution Profit Split
Method or Residual Profit Split Method).
Based on Article 11 paragraph (12) PER-32 / PJ / 2011, the PSM method can only
be applied in the following conditions:
a. Transactions between parties that have special relationships are
closely related to each other, so studies are not possible separately;
or
b. There are unique tangible items between the parties that transact
which cause difficulties in finding the right comparison data.
This method is most appropriate when taxpayers and related parties develop
valuable intangible assets that contribute to the total profit (or loss) of a
transaction or when a transaction cannot be analyzed separately because of the
very high level of integration.
The PSM method identifies the combined profit (or loss) obtained by the parties
involved and then divides the profit (or loss) to those parties in accordance with
the value of their economic contribution to the transaction. The value of the
economic contribution is determined based on the expected rate of return by an
independent party if it performs a comparable function, uses comparable assets

Page 52
and skills, and carries equal risks. It should be remembered that transactions
tested using the PSM method are usually unique and there may not be an
external comparison available to test the determination of the value of the
related economic contribution. Testing the determination of the value of
economic contributions may be more on subjective measurements based on the
facts and conditions of each case.
The combined profit (or loss) used in the application of the PSM method is a
combination of operating profit (or loss) obtained by each party involved in the
affiliate transaction being tested. The profit (or loss) obtained by each party must
be separated from the profit (or loss) they get from other transactions.
Therefore, if the parties other than make transactions to conduct the tested
transaction also carry out other transactions, the income and expenses
contained in the income statement must be segmented.
However, the PSM method will be very difficult to implement if there are
difficulties in accessing information from affiliated parties abroad. In addition,
there are difficulties in measuring the combined income and costs of all
companies participating in affiliate transactions, especially in adjusting
accounting practices and the currencies of the affiliated companies involved.
In this document, the PSM method cannot be used because information on

affiliated parties that are overseas is difficult to access so it is difficult to measure
the combined income and costs and it is difficult to determine the value of
economic contributions of all companies participating in affiliate transactions.
7.1.5 TNMM Method (“Transactional Net Margin Method”)

Based on Article 11 paragraph (7) PER-32 / PJ / 2011, the TNMM method is a
method of transfer pricing conducted by comparing the percentage of operating
net income to costs, to sales, to assets or to other bases of transactions between

Page 53
parties that have special relationship with the percentage of operating net
income earned on a comparable transaction with another party that does not
have a special relationship or percentage of operating net income earned on a
comparable transaction made by a party that has no other special relationship.
The right conditions in applying the TNMM method based on Article 11
paragraph (13) PER-32 / PJ / 2011 are among others:
a. One party in a special relationship transaction makes a special
contribution; or
b. One party in a special relationship transaction conducts complex
transactions and has transactions related to each other.
The TNMM method can be applied directly or indirectly to test many types of
affiliate transactions (including royalties, loans, services and tangible goods
transactions). The TNMM method can also be applied flexibly both on a per
transaction basis and on the basis of the overall operating profit.
The level of profit tested for its fairness in the TNMM method is operating profit
(net profit margin) for affiliate transactions. This is what distinguishes the TNMM
method with the CPM method and RPM that uses the gross profit rate as a
fairness reference. The use of operating profit as a fairness reference is due to
the level of profit that is more tolerant of differences in functions between
affiliated and independent transactions, because the different functions are
generally reflected in operating costs. In addition, differences in the classification
of costs at the level of gross profit among countries where affiliates are
domiciled can be avoided by using the level of operating profit. However, the
comparability for the functions performed, the assets used and the risks borne
still need to be considered.
The use of the TNMM method is that comparable companies that make

Page 54
comparable transactions will tend to get comparable returns over a certain
period.
To apply the TNMM method it is necessary to look for comparative data. The use
of internal comparators in the TNMM method is very rare. This is because not all
transactions conducted with independent parties can be used as a reliable
comparison to be compared with affiliate transactions conducted by the
company. In addition to internal comparison, we can also use external
comparison data that can be obtained from commercial databases. In this
document, an ORBIS database is used to look for external comparison candidates
who will be manually filtered to get a company that is comparable to the party
being tested.
Transactional Net Margin Method (TNMM) was chosen as the most appropriate
method for analyzing transfer pricing in affiliate transactions conducted by CDB
in accordance with the principle of fairness and prevalence of business. The
analysis was carried out by comparing the Net Cost Plus (NCP) CDB to the
comparable independent Weighted Average Net Cost Plus (WANCP) range of
companies obtained from third-party databases, the TP Catalyst Orbis. The
affiliate transaction included in the analysis is a sales transaction.
The interquartile range of WANCP for 2013 to 2015 from comparison companies
is 1.64% to 7.99% with a median value of 4.90%. In 2017, the adjusted CDB NCP
is 4.50%. Based on this analysis, the adjusted 2017 CDB NCP is in the interquartile
range of comparable data. Thus, it can be concluded that the determination of
the transfer price of the affiliate transactions included in this analysis is in
accordance with the principle of fairness and prevalence of the business.

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7.2 Application of TNMM
7.2.1 Parties Analyzed (Tested Party)

The interquartile range of WANCP for 2013 to 2015 from comparison companies
is 1.64% to 7.99% with a median value of 4.90%. In 2017, the adjusted CDB NCP
is 4.50%. Based on this analysis, the adjusted 2017 CDB NCP is in the interquartile
range of comparable data. Thus, it can be concluded that the determination of
the transfer price of the affiliate transactions included in this analysis is in
accordance with the principle of fairness and prevalence of the business.
7.2.2 Selection of Profit Level Indicators

Profit Level Indicators (PLI) is a ratio that measures the relationship between
profits earned by a company on costs incurred. The application of TNMM requires
the selection of the appropriate PLI. The selection of PLI is determined by the type
of business activity of the company and the availability of comparative data.
The following table shows the PLI used.
Ratio Formula Description
The NCP ratio is rated as the most

Operating profit / appropriate PLI when total costs are the
(Cost of goods main driver of profitability for the party
Net Cost Plus
sold / services + being tested. NCPs are often used in service
(“NCP”)
operating costs) provider companies .
Table 15 - PLI Chosen
7.2.3 Overview of Financial Statements

The following is an overview of the CDB financial statements for 2017.
Table 16 - Summary of the 2017 CDB Financial Report
2017
Income Summary
(Rupiah)
Income 270.889.898.467

Page 56
Cost Of Goods Sold 213.157.910.949
Gross profit 57.731.987.518
Gross Profit Margin 21,31%
Operating Expense 46.090.438.524
Operating Profit (Loss) 11.641.548.994
NCP 4,49%
7.2.4 Data Sources
In the application of TNMM analysis, the external comparative data used is the
comparative financial data obtained from third-party sources, namely the TP
Catalyst Orbis (update as of January 2017).
7.2.5. Process of Finding Comparison

The purpose of the comparator search process is to identify independent
companies that have business profiles that are comparable to CDB.
7.2.6 Comparison Search in TP Catalyst

Search comparison on the TP Catalyst Orbis is done using a search strategy
consisting of several criteria. The following are the criteria used in the search
strategy.
1. Company Status
Within the TP Catalyst Orbis there are many companies, both active
and non-active companies. In this search strategy only companies that
have criteria as active companies are selected. This criterion serves to
set aside inactive companies from comparative candidates.
2. Industrial Code

Page 57
The industrial code used in the search strategy is United States Standard
Industrial Classification (US SIC). The following table presents the selected
US SIC codes that match the CDB business profile used in this analysis.
Table 17 - US SIC TP Catalyst
US SIC Keterangan
231 Men's and boys' suits, coats and overcoats

Men's and boys' furnishings, work clothing and allied
232
garment
233 Women's, misses' and juniors' outerwear
234 Women's, misses', children's and infants undergarments
236 Girls', children's and infants' outerwear
Sumber: osha.gov2
3. Independence Indicator
Independence indicators are used to eliminate companies that are

under the control of other companies because these companies have
the potential to have issues regarding transfer prices and therefore
cannot provide an indication of a reasonable rate of return.
The independence indicators available on the TP Catalyst Orbis are

explained as follows:
Table 18 - Types of Independence Indicators
Indicators Explanation
No shareholder has more than 25% direct

A+, A, A-
ownership.
No shareholder has more than 50% direct,

indirect or overall ownership. One or more
B+, B, B-
shareholders have more than 25% direct
ownership.
2United States Department of Labor, SIC Division Structure,

https://www.osha.gov/pls/imis/sic_manual.html
Page 58
Indicators Explanation
No shareholder has more than 50% direct

C+, C ownership. One shareholder has ownership
of more than 50%
One shareholder has more than 50% direct

D
ownership.
U Shareholders are recorded as Unknown.
In this report, the independence indicators used to find similar

companies are A (A +, A, A-). Companies classified into
independency indicators B (B +, B, B), C (C +, C), D, and U will be
eliminated.
1) Account Type
Within the TP Catalyst Orbis, there are companies that have one or more
types of financial information. The types of financial information available
on the TP Catalyst Orbis are as follows:
Table 19 - Types of Financial Information
Consolidation Code explanation
Financial information is available in the

C1
form of consolidated financial statements.
There are 2 (two) types of financial

information (consolidated financial
C2/U2
statements and unconsolidated financial
statements).
Financial information is available in the
U1 form of unconsolidated financial
statements.

Page 59
2) In this report, only companies that have financial information
with codes U1 and C2 / U2 are used in the analysis. This criterion
serves to analyze the reasonableness and prevalence of CDB
businesses as an entity (single entity).
3) Available Data and Information
4) Regulations related to transfer prices in Indonesia have adopted

an ex-ante approach and therefore the report preparation
process must be based on data and information available at the
time the transaction was conducted. The most up-to-date data
and information available on the Orbis TP Catalyst for updates as
of January 2017 are financial data and information for 2015.
Therefore, companies that have at least 3 (three) accounting
years with the final year of 2015 will be used in the analysis.
5) Availability of Business Information Candidates for comparison

companies must have company business information. Therefore,
companies without company business information will be
eliminated.
6) Textual Search
Only companies that meet the text search criteria ("knit",

"knitting") will be selected as potential comparison companies.
Based on the above criteria, there are 130 (one hundred and thirty)
candidates for comparison companies.
7.2.5.1 Manual Selection

1. The next stage is the process of selecting comparison companies obtained
from the TP Catalyst Orbis manually. Manual selection is done to determine
whether the candidate comparison company is comparable and can be used
as a comparison. Manual selection conducted consists of 2 (two) selection
processes, namely quantitative review and qualitative review.
2. Quantitative Review
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At this stage, the search focuses on the quantitative criteria as follows:
1) Significant R & D Activities
The tested party does not carry out research and development / R & D
functions. Therefore, candidates for comparison companies that have
significant R & D activities (assuming the ratio of R & D expenses to
revenues of more than 1% are significant R & D activities) will be
eliminated as a comparison company.
2) Continuous Operating Losses
Companies that experience operational losses for 3 (three) consecutive
years will be eliminated as comparison companies. This is due to doubts
about the going concern of the company.
3) Insufficient Financial Information
Companies that have inadequate financial information will be eliminated

as a comparison company considering that comparative analysis of the
comparison cannot be carried out reliably.
At this stage, 28 (twenty eight) comparative company candidates were

eliminated as comparison companies.
3. Qualitative Review
At this stage, the search focuses on qualitative criteria using data

provided by commercial databases. In addition, analysis is also carried out
using information obtained from other media. The qualitative criteria
used are as follows:3
A) Difference in Function
Candidates for comparison companies that have criteria for
3In most cases, comparative analysis will adjust to the availability of data given that it is not possible to find
a company with the same product and type of business. Therefore, to improve comparability and to enable
the application of TNMM in this report, in the benchmarking process companies are selected with products
and business profiles that substantially resemble.
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different functions will be significantly eliminated as comparison
companies.
B) Product Differences
Candidates for comparison companies that have different

product criteria will be significantly eliminated as a comparison
company.
At this stage, 83 (eighty three) comparative company candidates

were eliminated as comparison companies.
4. List of Comparative Companies
After manually selecting candidates for comparison companies, 19

(nineteen) companies were selected as comparison companies.
Table 20 - List of Final Comparative Companies
No Company name Region

1 BANDO INC CO.,LTD. Republic of
Korea
2 BANNU WOOLLEN MILLS LIMITED Pakistan
3 BINHAI SALES CO., LTD. China
4 CARNIVAL INDUSTRIAL CORPORATION Taiwan
5 COMME DE GAMME CO.,LTD. Republic of
Korea
6 ECLAT TEXTILE CO., LTD. Taiwan
7 KALIM COMPANY CO.,LTD. Republic of
Korea
8 KNF INTERNATIONLAL CO.,LTD. Republic of
Korea
9. KOCH INTERNATIONAL CO.,LTD. Republic of
Korea
10. MAKALOT INDUSTRIAL CO., LTD. Taiwan
11. MONTE CARLO FASHIONS LIMITED India
12. NISHIMATSUYA CHAIN CO.,LTD. Japan
13. NOBLE INDUSTRY CO.,LTD. Republic of
Korea
14. PEPLOS Russian
Federation
15. SEONG AN CO.,LTD. Republic of
Korea
16. SU INTERNATIONAL CO.,LTD. Republic of
Korea
17. SUHYANG NETWORKS CO.,LTD. Republic of
Korea
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18. THE WILLBES & CO.,LTD. Republic of
Korea
19 WORLVI TRADING CO.,LTD. Republic of
Korea
Additional Comparative Company
CDB comparison companies from the 2016 TNMM analysis will be added to
this analysis. The comparison company is The Willbes & Co., LTD. which is a
company from Japan.
7.2.5 Multiple Year Data and Weighted Interquartile Average Range

Analysis is carried out on several years of financial data from comparison
companies to reduce the impact of short-term variations that have nothing to do
with the determination of transfer prices in a 1 (one) year performance and to
capture the impact of the business comparison company. In general, the data
cycle of 3 (three) years is calculated to obtain a weighted average from the PLI.
This is in accordance with Chapter II PER-22 / PJ / 2013 which states that:
“To determine the reasonableness of an affiliate transaction, comparing the

year per year can be distorted due to material differences in the economic
situation or market conditions and other conditions in the company.
Testing for the fairness of a transaction, requires research of several years of

data on affiliate transactions or independent transactions. In this way,
differences occur because some things such as the product cycle or business
cycle can be overcome and will produce more reliable proportions.”
Therefore, a weighted average of 3 (three) years (2015, 2014 and 2013) was used
for this analysis. Statistical analysis on the fairness of profitability is done using
interquartile ranges. The interquartile range refers to the spread of available
data ranges, which consist of the range between the 25th percentile and the
75th percentile as a result of the comparison.

Page 63
The use of ranges is intended to reduce the impact of differences in business
characteristics between the parties being tested (tested party) and its
comparison because the range allows results obtained in a variety of commercial
and financial conditions. Therefore, interquartile ranges are considered as a
measure of the appropriate fairness range when a sample of independent
companies consists of similar companies with tested parties, but differ in one or
several significant matters.
7.2.6 Adjustment of CDB Comparison

Comparative adjustments aim to increase the level of reliability of a comparison
of selected comparison companies. Based on PER-22 / PJ / 2013, comparative
adjustments can be made if there are factors that affect the condition of prices
or earnings substantially for affiliated and independent party transactions. The
following are adjustments made by CDB in 2017, among others:
Claim Expenses
In the audit report, based on operating expenses. CDB has a claim expense of Rp
21,380,763. For that condition, the following PLI calculation after adjustments
were made:
Table 21 - Summary of Financial Reports After Adjustment
Before After
Adjustment
Description Adjustment Adjustment
(rupiah) (rupiah) (rupiah)
Income 270.889.898.467 270.889.898.467
Cost Of Goods Sold 213.157.910.949 213.157.910.949
Gross Profit 57.731.987.518 57.731.987.518
Claim Expenses 46.090.438.524 46.090.438.524
Adj.: Claim Expenses 21.380.763 21.380.763
Total Operating Expenses 46.069.057.761
Operating Profit 11.641.548.994 11.662.929.757
Net Cost Plus (NCP) 4,49% 4,50%

Page 64
7.2.7 Analysis Results
The application of TNMM was carried out by comparing the 2017 CDB NCPs that
were adjusted to the WANCP interquartile range of comparison companies in
2013-2015. The following table presents the interquartile range for WANCP
2013-2015 from 37 (thirty seven) comparison companies.
Table 22 - Analysis Results
Comparative Company
1 BANDO INC CO.,LTD. 7,99% 7,90% 7,01% 9,26%
BANNU WOOLLEN MILLS 14,61% 14,86% 15,12% 13,89%
2 LIMITED
3 BINHAI SALES CO., LTD. 6,35% -0,21% 0,84% 8,33%
CARNIVAL INDUSTRIAL -1,42% -1,86% 0,13% -2,37%
4 CORPORATION
5 COMME DE GAMME CO.,LTD. 6,42% 9,90% 5,57% 3,72%
6 ECLAT TEXTILE CO., LTD. 21,85% 23,21% 21,17% 20,88%
7 KALIM COMPANY CO.,LTD. -5,24% -36,30% -0,15% 12,37%
8 KNF INTERNATIONLAL CO.,LTD. 6,50% 6,10% 6,01% 7,65%
KOCH INTERNATIONAL 10,66% 13,03% 10,93% 6,52%
9 CO.,LTD.
MAKALOT INDUSTRIAL CO., 10,88% 12,18% 10,45% 9,87%
10 LTD.
MONTE CARLO FASHIONS 18,25% 17,46% 18,88% 18,44%
11 LIMITED
NISHIMATSUYA CHAIN 4,44% 4,66% 4,31% 4,35%
12 CO.,LTD.
13 NOBLE INDUSTRY CO.,LTD. 9,39% 8,65% 9,08% 10,68%
14 PEPLOS 1,99% 6,88% 1,51% 0,07%
15 SEONG AN CO.,LTD. -1,57% -1,14% -4,56% 0,86%
16 SU INTERNATIONAL CO.,LTD. 9,74% 11,99% 9,69% 7,21%
17 SUHYANG NETWORKS CO.,LTD. 4,53% 4,71% 4,48% 4,38%
18 THE WILLBES & CO.,LTD. 1,30% -0,80% 1,87% 3,32%
19 WORLVI TRADING CO.,LTD. -2,24% -7,00% -5,03% 3,28%
WANCP
NCP
Statistical Value 2013- NCP 2015 NCP 2014
2013
2015
Number of observations 19 19 19 19
(company)
Maximum 21,85% 23,21% 21,17% 20,88%
Upper Quartile 10,20% 12,09% 10,07% 10,27%
Median 6,42% 6,88% 5,57% 7,21%
Lower Quartile 1,65% -0,50% 1,18% 3,52%

Page 65
Minimum -5,24% -36,30% -5,03% -2,37%
The interquartile range of WANCP for 2013 to 2015 from comparison companies is
1.65% to 10.20%, with a median value of 6.42%. In 2017, the adjusted CDB NCP is
4.50%. Based on this analysis, the adjusted CDB NCPs are in the interquartile range
of comparable data. Thus, it can be concluded that the determination of the
transfer price of the affiliate transactions included in this analysis is in accordance
with the principle of fairness and prevalence of the business.

Page 66
ATTACHMENT
Attachment A - Search Comparison in The Orbis Catalyst di TP Catalyst Orbis
A.1. Search Startegy

Page 67
Attachment B - Manual Selection
B.1. The Company Eliminated at Quantitative Review

R&D Insufficient Loss for 3
No. Company name Activity Financial Years
>1% Information Consecutive
1 AKANSHA GROWTH FUND PVT.LTD. x
2 BIRLA COTSYN (INDIA) LIMITED x
3 CHUWA WOOL INDUSTRY CO., TAIWAN LTD. x
4 C'SMEN CO.,LTD. x
5 DAEAN CO.,LTD. x
6 EVERGREEN TEXTILES LIMITED x x
7 FAR EASTERN NEW CENTURY CORPORATION x x
8 GNCO CO.,LTD. x
9 HYUNGJI ELITE INC. x
10 ILJEONG INDUSTRIAL CO.,LTD. x
11 JAYASWAL NECO METALLICS PRIVATE LIMITED x
12 KUMI INTERNATIONAL CO.,LTD. x
13 LILONTEX CORPORATION x
14 MEGA BIOTECH & ELECTRONICS CO., LTD. x x
15 NAIGAI CO.,LTD. x
16 NAMYEUNG VIVIEN CORPORATION x
17 NAN YANG DYEING & FINISHING CO., LTD. x
18 OROTONGROUP LIMITED x
19 PRIYADARSINI LIMITED x
20 RYU KYUNG INDUSTRIAL. CO.,LTD. x
21 SAN SHING SPINNING CO., LTD. x
22 SUKWANG CORPORATION x
23 TAH TONG TEXTILE CO., LTD. x
24 TBH GLOBAL CO.,LTD. x
25 THOMAS SCOTT (INDIA) LIMITED x
26 TOP UNION ELECTRONICS CORPORATION x
27 TRI OCEAN TEXTILE CO., LTD. x x
28 WONPUNG MULSAN CO.,LTD. x

Page 68
B.2. The Company Eliminated at Qualitative Review
Company Eliminated Due to Different Functions
Different
No. Company Name Business Activity
Functions
1 ADVANCETEK ENTERPRISE CO LTD Services x
2 AKKUS TEKSTIL SANAYI TICARET ANONIM SIRKETI Manufacturing; Wholesale x
BEIJING LIJIA LIYING CHAPTERY PRODUCTS CO., Retail
3 x
LTD.
4 DAIDOH LIMITED Manufacturing; Wholesale x
5 DECO & E CO.,LTD. Manufacturing; Wholesale x
6 EAGLE COLD STORAGE ENTERPRISE CO., LTD. Wholesale x
7 EURO ASIA EXPORTS LIMITED Wholesale x
8 EVERTEX FABRINOLOGY LTD. Services x
9 GOOD PEOPLE CO.,LTD. Manufacturing; Wholesale x
10 HIRA TEXTILE MILLS LIMITED Manufacturing; Wholesale x
11 HONG YI FIBER INDUSTRIAL CO., LTD. Manufacturing; Wholesale x
12 ICHIKURA CO.,LTD. Retail x
INDIAN TERRAIN FASHIONS LIMITED Manufacturing; Wholesale;
13 x
Retail
14 J L MORISON (INDIA) LIMITED Wholesale x
15 KING CO.,LTD. Wholesale x
16 LUT CORPORATION Wholesale x
17 S.M.K. INTERNATIONAL CO.,LTD. Manufacturing; Wholesale x
18 MARUKA MACHINERY CO.,LTD. Wholesale x
19 MASTERS CORPORATION Wholesale x
20 MOONBAT CO.,LTD. Wholesale x
21 PEGASUS SEWING MACHINE MFG CO.,LTD. Manufacturing; Wholesale x
22 POTREBITELSKOE OBSHCHESTVO KOOPERATOR Retail x
23 RED FACE CO.,LTD. Wholesale x
24 SBW INC. Manufacturing; Wholesale x
25 SMARK CO.,LTD. Services x
26 SPENTA INTERNATIONAL LIMITED Manufacturing; Wholesale x
27 SUPER TANNERY LIMITED Manufacturing; Wholesale x
28 SURGUTNEFTEGAS JOINT STOCK COMPANY Manufacturing; Services x
29 TAKATORI CORPORATION Manufacturing; Wholesale x
30 TARUN INTERNATIONAL LIMITED Services x
31 WISHER INDUSTRIAL CO., LTD. Manufacturing; Wholesale x
32 ZAKRYTOE AKTSIONERNOE OBSHCHESTVO TSUM Retail x

Page 69
Attachment C - Company Eliminated Due to Different Business Profile
Different
Reason for
No. Company Name Business Description Business
Rejection
Profile
1 ABDIOGULLARI The company is a Turkey based enterprise x Perbedaan profil
PLASTIK VE engaged in the manufacture of plastic packing usaha.
AMBALAJ SANAYI goods. The company was incorporated in the Perusahaan ini
ANONIM SIRKETI year 1993. Its registered business office is based bergerak dalam
in Adana, Turkey. It is registered as a limited pembuatan
company.The company comprises its business barang kemasan
activities in the manufacture of bags of plastik.
unsupported plastics film, coated paper, metal
foil, or laminated combinations of these
materials. It is also involved in the manufacture
of uncoated paper bags and multiwall bags and
sacks.
2 ARIKAN The company is engaged in the manufacture of x Perbedaan profil

MENSUCAT cotton yarn. The company was established as an usaha.
SANAYI VE TICARET open end yarn and open end spinning mill Perusahaan ini
ANONIM SIRKETI factory in 1993. It has its registered business terlibat dalam
office in Kahramanmaras, Turkey. The company pembuatan
has 12 state-of-the-art technology machines benang katun.
with a production capacity of approximately Perusahaan ini
12,000 kilograms per day in a 6,000 square- didirikan sebagai
meter closed area. All of its machines are pabrik benang
RIETER and have USTER UPG 5.The company open end dan
produces knitted fabrics from 100 percent pabrik
cotton, poly-cotton, viscose, poly-viscose, pemintalan akhir
polyester yarns with or without Elestan; 100 terbuka.
percent cotton open end, ring carded and
combed raw yarn for weaving and knitting; and
dyed yarn for knitting and weaving. Its goal is to
provide best service in terms of price, quality
and respectful for the natural life in order to be
the best supplier and in domestic market.The
company sources materials from European
countries, mainly from Portugal and Italy.
Except for Portugal and Italy, it exports its
products to the leading markets of the world,
namely Greece, Spain, Poland, Hungary,
Slovakia and Bulgaria.

Page 70
Different
Reason for
Rejection
Profile
3 ASICS The company is engaged in the manufacture x Perbedaan profil
CORPORATION and marketing of general sporting goods, shoes, usaha.
and equipment in Japan. The company was Perusahaan ini
founded in 1977 through the merger of Onitsuka terlibat dalam
(a manufacturer of sports shoes), GTO (an pembuatan dan
equipment manufacturer), and JELENK ( a sports pemasaran
apparel manufacturer). Its head office is located barang-barang
in Kobe City, Japan. The company is one of the olahraga umum,
industry's leading total sports products sepatu, dan
manufacturers in Japan. It also produces shoes peralatan di
designed for football, running, tennis, martial Jepang.
arts, cricket, golf, wrestling, track and field,
cross-training, volleyball, cheerleading, and for
many other sports. The company aims to
provide products and services that offer value to
every customer. The company has branch offices
located in Kanto (Sumida-ku, Tokyo), and Kansai
(Amagasaki City, Osaka), as well as sales
representatives in North Kanto (Saitama City),
Hiroshima (Hiroshima City), and Shikoku
(Takamatsu City). Its overseas companies are
located in the United States, Europe, Australia,
and China.
4 ATSUGI CO.,LTD. The company is primarily engaged in the x Perbedaan profil
manufacture of pantyhose, socks and lingerie. usaha.
Established in December 1947, its shares were Perusahaan ini
listed on the second section of the Tokyo Stock terutama
Exchange in October 1951 and the first section bergerak dalam
of Osaka Stock Exchange in October 1962. The pembuatan
shares were transferred to the first section of pantyhose, kaus
the Tokyo Stock Exchange in October 1963. The kaki dan pakaian
company's corporate heaquarters is located in dalam
Kanagawa, Japan.The company has three
business divisions: pantyhose and socks,
lingerie, and elderly care products. It has a wide
variety of products in the area of socks. The
company's major products in this field are
ribbed socks. It provides a lineup for all
consumers, which include women, children and
men. The company's manufacturing system
integrates thread processing and dyeing,
knitting, pairing, setting, inspection, and
packaging.The company offers a variety of
lingerie based on the generation and lifestyle. It
focuses on the age concept segment for each
generation. The company is involved in product
development that applies analysis of trends in
the fashion market, research on women's
preferences in each stage life, and actual
customer opinions collected in stores. It has
entered in a field by using technology it has
developed for the production of pantyhose,

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socks, and lingerie. The company has developed
a portable deodorizing toilet.
5 BITEKS IPLIK The company is engaged in the manufacture x Perbedaan profil

SANAYI VE TICARET and sale of textile fibers. It was founded in 2007 usaha.
ANONIM SIRKETI and it conducts business from its registered Perusahaan ini
head office which is strategically located in terlibat dalam
Osmaniye, Turkey.The company is primarily pembuatan dan
involved in the following activities: penjualan serat
manufacturing noncellulosic, such as nylon, tekstil.
polyolefin, and polyester fibers and filaments in
the form of monofilament, filament yarn, staple,
and tow; and manufacturing and texturizing
noncellulosic fibers and filaments. Moreover,
the company produces rayon and acetate fibers
in the form of monofilament, yarn, staple, or
tow. These fibers are suitable for further
manufacturing in other industries on spindles,
looms, knitting machines, or other textile
processing equipment.
6 BYC CO.,LTD. The company is engaged in the manufacture x Perbedaan profil
and distribution of men and women and usaha.
children's underwear in Korea and other foreign Perusahaan ini
countries. The company was founded in 1946. terlibat dalam
Its registered head office is located in Seoul, pembuatan dan
Republic of Korea. The company serves as the distribusi
leading enterprise in the underwear industry in pakaian pria dan
Korea and the largest underwear exporter in the wanita dan anak-
world. The company produces underwear under anak di Korea
BYC, Scorpio, Mosimeri, Airmeri, Deonia, Leson dan negara-
and Amie brand names. The company's negara asing
products are distribute in approximately 70 lainnya.
countries worldwide, including the Middle East,
Africa, Japan and the United States. The
company is also involved in the operation of
specialty stores in Jordan, Bahrain and Japan.

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The company operates more than 100 plants in
throughout Korea, specifically located in Seoul,
Jeonju and Iseo, as well as established plants in
China, located in Songgang, Hwayanggyo and
Gaseon. The company, with approximately
6,000 sewing workers, has a production
capacity of more than 100 million pieces of
underwear per year. Its goal is to further
contribute to the clothing life of people and to
become the world's best high-tech garment
manufacturer.
7 CHONBANG The company is a publicly quoted firm primarily x Perbedaan profil
CO.,LTD. engaged in the manufacture of yarn and fabrics. usaha.
The company was established in February 1953 Perusahaan ini
as Chonnam Spinning Co., Ltd. Its headquarters adalah
is located in Seoul, Korea. In 1968, the company perusahaan
is listed on the Korea Stock Exchange and publik yang
founded the Incheon factory which began its terutama
operations for worsted and cotton spinning..The bergerak dalam
company's products include yarn (cotton yarn, pembuatan
tencel yarn, modal yarn, lenzing LYocell yarn, benang dan kain.
open-end yarn, cleaniber silver yarn); dyed yarns
(mercerized yarn, space dyed yarn, dyed yarn,
indigo dyed yarn); embroidery threads
(embroidery threads and sewing threads); fabric
(denim, modal, tencel, span, cotton fabric); knit;
and raw materials (cotton, tencel, modal,
Lyocell). It trades its products under the
following brands: Hempia, Silroyal, Royal,
Cleaniber, and Newstar. The company's facilities
include Gwangju Factory, Yeongam Factory,
Siheung Factory, and Cheonan Factory. As of
December 2006, the company had an annual
production capacity of 32,537 tons of yarn and
10,184 kilo meters (km) of fabrics and its actual
production output was 30,162 tons of yarn and
8,901 km of fabrics.
8 CHUNG SHING The company is a publicly quoted firm based in x Perbedaan profil
TEXTILE CO., LTD. Taiwan which is engaged in chemical fiber usaha.
manufacturing, yarn spinning, weaving, dyeing Perusahaan ini
and printing and garment manufacturing. It was adalah
established in 1956 and has its registered head perusahaan
office strategically located in Taipei City, publik yang
Taiwan. The company's common shares are berbasis di
traded on the Taiwan Stock Exchange under the Taiwan yang
securities code 1408.The company's chemical bergerak di
fiber products include polyester textured yarn, bidang
polyester pre-oriented yarn, polyester staple manufaktur serat
fiber, nylon, and filament sizing yarn. It also kimia,
produces cotton products, knitted garments, pemintalan
pullover, tops, pants, shorts, dresses, and skirts. benang,
The company markets its products in national penenunan,

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and international markets under the brand pencelupan dan
name Three Gun.The company is a member of pencetakan serta
the International Trade Association of the manufaktur
Republic of China, an international non-profit garmen.
organization that promotes export activities for
the economic improvement of Taiwan.
9 FORMOSA The company is a Taiwan-based enterprise x Perbedaan profil

PLASTICS engaged in the production of plastic-related usaha.
CORPORATION products. It was established in 1954 and has its Perusahaan ini
corporate head office located in Taipei, Taiwan. adalah
The company's products include resins, VCM perusahaan yang
(vinyl chloride monomer), caustic soda, and berbasis di
hydrochloric acid, MBS, HDPE (high-density Taiwan yang
polyethylene), EVA (ethylene-vinyl acetate) and terlibat dalam
LLDPE (low-density polyethylene). These produksi produk-
products are marketed in China, Hong Kong, produk yang
Southeast Asia, Australia, the United States, berhubungan
Middle East and Northeast Asia. The company's dengan plastik.
operations are carried out through its seven
business units: plastics, polyolefin,
polypropylene, Tairylan, chemicals, carbide and
engineering and construction. It is the largest
PVC (polyvinyl chloride) resin producer in
Taiwan. Its manufacturing sites include
Kaohsiung, Jenwu, Linyuan, Tungshan, Sanshai,
Hsinkang and Mailiao.
10 FUJIAN HAIXIA The company is engaged in the production of x Perbedaan profil
TEXTILE yarn. It was incorporated in the year 2011. It usaha.
TECHNOLOGY CO., has its registered business office as well as its Perusahaan
LTD. production facilities located in Putian, China.The bergerak dalam
company's products include pure spin yarn, produksi benang.
viscose yarn, wicking yarn, and blended yarn. It
has advanced technology and equipment for
manufacturing, as well as employs certified staff
skilled in manufacturing operations in
compliance with the standards and other
technical specifications. Its products are sold
and distributed in domestic market as well as
overseas through its comprehensive marketing
network.

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11 GOLDWIN INC. The company is a leading manufacturer of the x Perbedaan profil
highest quality of authentic sportswear and bisnis.
equipment. It started in 1951, when Mr. Tosaku Perusahaan ini
Nishida established a knitting company.Since adalah produsen
the foundation, the company developed a terkemuka dari
vertical production structure to process raw pakaian dan
materials to clothing with a strong emphasis perlengkapan
placed on quality. This proved successful and autentik
since the Olympiad held in Tokyo in 1964, it has berkualitas
supported many large sports events by offering tertinggi
quality apparels. Currently, the company
supports many famous athletes. From the
1970's on, its growth was accelerated by
introducing to Japan many famous foreign
brands under license.The company offers a
variety of clothing such as ski, athletic, tennis
and outdoor apparels to name a few. These
lines carry the following trademarks which are
owned by the company: Goldwin, Blue Blood,
Estivo, Laterra, Profecio, Athloid, Slow-Flow and
others. In addition, it also carries brands under
license agreement, including Champion, Speedo,
Helly Hansen, Eastpak, Coleman apparel and
Fischer.With a hometown plant in Japan as the
main base, it has plants in China and Southeast
Asia.
12 HANSON The company, with registered office address in x Perbedaan profil
INTERNATIONAL Jakarta, is an Indonesian firm engaged in the usaha.
TBK., PT textile industry. It was incorporated in July of Perusahaan ini
the year 1971.The firm specializes in the adalah
manufacture and trade of ready to wear perusahaan
garments. It involves knitting, weaving, export publik bergerak
and import, local trading, retailing, wholesaling dalam industry
and distribution of textile products. The textile
company conducts its production operations in
Jakarta factory. It offers a wide range of apparel
products such as men's clothing, women's
clothing, pants, underwear, sleeping wear, bed
sheets, and other related apparel. These
products are exported to countries in Europe,
the United States, Asia and the Middle East. One
of the company's subsidiaries is PT Primayudha
Mandirijaya, a private company primarily
engaged in the spinning of yarn.

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13 H P COTTON It is an India-based company engaged in the x Perbedaan profil
TEXTILE MILLS manufacture and trade of yarns and threads in usaha. Ini adalah
LIMITED India and abroad. The company, with registered perusahaan yang
head office located in Hisar, India, was berbasis di India
established in 1985.It is one of the largest yang terlibat
producers and exporters of 100 percent cotton dalam
sewing thread, cotton and glaced pembuatan dan
threads&cotton gassed (singed) and mercerised perdagangan
yarns in India. Its gazed and mercerized yarn is benang dan
used for knitting, weaving, lace material, benang di India
fashion garments, T-Shirts, and socks; and dan luar negeri.
industrial thread, which is used in stitching, kite
flying, and embroidery. Its sewing threads come
in fashionable bright colors and are resistant
against washing and light, and are offered in
different sizes and shapes. The crochet and hand
knitting yarns are made of long fiber cotton and
are used for knitting curtains and bed covers,
which are offered in brilliant, high luster and
resistant colors. The company's industrial
threads are made from high quality cotton with
high resistance and extra long fiber. The
products are offered in different shapes and
sizes and used for stitching, embroidery and kite
flying. It produces approximately six million kg.
of ring spun, 100 percent sewing thread silk and
threads per annum, ranging from 10's to 60's
counts in single and multiple, cabled and folded
combed quality. The company markets its
products in India and exports to North America,
South America, Europe, Southeast Asia, Middle
East, Africa and Oceania.
14 HIGH STREET The company is an India-based enterprise x Perbedaan profil
FILATEX LIMITED engaged in the manufacture and sale of knitted usaha.
socks and other related products. It operates its Perusahaan ini
business primarily in India. The company was adalah
incorporated in the year 1994. Its registered perusahaan yang
business office is based in Jaipur, India. It is berbasis di India
registered as a limited company. yang terlibat
dalam
pembuatan dan
penjualan kaus
kaki rajutan dan
produk terkait
lainnya.

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15 ILSHIN SPINNING The company is a Korean firm engaged in cotton x Perbedaan profil
CO.,LTD. spinning. It produces and sells yarns, dyeing, usaha.
and fabrics. Its yarn products include combed Perusahaan ini
cotton yarns and melange yarns, which are used adalah
for knitted wears, sweaters, socks, and woven perusahaan
wears; spun yarns, for elastic woven fabrics, Korea yang
elastic knitted fabrics, and elastic socks; bergerak di
modal/polyester yarns, used for Knitted bidang
products, woven products, and sweaters; lyocell pemintalan
yarns for knitting and sewing; thermolite-yarns, kapas. Ini
which are used to make sportswear and casual menghasilkan
wear; coolmax spun yarns, which are suitable dan menjual
for making sportswear and casual wear; benang,
blended yarns for knitting, textile, and sweaters; pencelupan, dan
and OE yarns, which are used primarily for kain.
coarse and rough fabrics, such as denim. The
company's dyeing products comprise dyed yarn,
including rayon-blended yarn, as well as cotton
yarn and cotton-blended yarn; and dyed fabrics,
such as cotton-knitted fabrics, cotton-blended
fabrics, and stretch-knitted fabrics. Its fabric
products include woven fabrics and knitted
fabrics. The company markets and sells its
products primarily in Korea, Hong Kong, and
Japan. The company was established in
November 1951. It has its headquarters in
Seoul, Korea. The company's operations in
Korea are represented by its wholly-owned
subsidiaries: Ilshin Industrial Development Co.,
Ltd. and Shindong Corporation.
16 IPEKER TEKSTIL The company is engaged in the manufacture x Perbedaan profil
TICARET VE SANAYI and sale of a range of textiles and other related usaha.
ANONIM SIRKETI products principally in Turkey. The company was Perusahaan ini
founded in the year 1930. The registered head terlibat dalam
office of the company is located in Bursa, pembuatan dan
Turkey.The company is a family-operated textile penjualan
producer. For over 70 years, it has been berbagai tekstil
producing high-quality fabrics for fashion wear. dan produk
The present factory in the industrial district of terkait.
Bursa is fully integrated; along with printing and
dyeing, its weaving and engraving departments
are all on the same site. All leading printing and
finishing techniques as well as its special unique
developments are used during the production
process. The company is a leading participant
on domestic and international markets
producing a variety of plain and printed fabrics
for high-class ladies' fashion, men's shirts and
scarves. The fabrics, certificated by ENKA,
BEMBERG and DUPONT, are produced using
artificial and synthetic fibres like Enka Rayon,
Bemberg Cupro and Dupont Lycra.

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17 IVY CLUB The company is engaged in the manufacture x Perbedaan profil
CORPORATION. and sale of clothing. It was incorporated in April usaha.
CO.,LTD. of 2013 and has its registered head office in the Perusahaan ini
city of Seoul in the Republic of Korea. The bergerak dalam
company's products include T- bidang
shirts/vests/sweats, jumpers/cardigans, jeans, pembuatan dan
shorts, trousers/leggings, and coats/jackets for penjualan
men and women; and dresses, skirts, pakaian.
playsuits/jumpsuits, tops, blouses/shirts, for
women, as well as polo shirts, suits, and chinos
for men. Its products are marketed and sold
throughout Korea and internationally in
cooperation with its local and foreign business
partners and affiliates.
18 JEMI AND F The company is engaged in the manufacture of x Perbedaan profil
CO.,LTD. apparel, accessories and other textile products. bisnis. Selain itu,
It also produces and sells trousers, work clothing ia mendesain,
and allied garments. Its products include polo memproduksi,
and rugby shirts, sweaters, and shorts; licensed dan memasarkan
and logoed sportswear; casual and dress slacks; t-shirt rajut
sweatshirts and T-shirts, which include khusus label
turtlenecks, boxers, anoraks, and sweaters; and pribadi terutama
outerwear, hats, backpacks, and bags. In untuk
addition, it designs, manufactures, and markets perusahaan
private label custom knit T-shirts primarily to olahraga
branded sportswear companies. The company bermerek.
sells its products to specialty and boutique
shops, upscale and traditional department
stores, mid-tier retailers and sporting goods
stores. The company offers its products under
various brands in the domestic and international
markets. Incorporated in December of 1989, it
was formerly known as Jemi Trading Co. Ltd.
The company has a registered office located in
Seoul, Republic of Korea.
19 JESSI & CO.,LTD. The company is primarily engaged in the x Perbedaan profil
manufacture of women's outerwear products. usaha.
The company, established in March of 1998, Perusahaan ini
was formerly known as Bluejong Inc Co., Ltd. terutama
The registered head office of the company is bergerak dalam
located in Seoul, Republic of Korea.The company pembuatan
aims to bring a sexy, modern and casual look to produk pakaian
enjoy every day that can be carried from the day luar wanita.
time right into the night time. The company
manufactures a wide range of outerwear
products, such as blouse, polo shirt, T-shirt, coat
and tie, hood and jacket, sweater, shorts, skirt,
and jeans, among many others. The company
predominantly operates in the domestic market.

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20 K H EXPORTS INDIA The company is engaged in manufacturing and x Perbedaan profil
PRIVATE LIMITED exporting leather goods. It was incorporated in usaha.
May of 1985 and has its registered business Perusahaan ini
office strategically located in Chennai, India. It is bergerak di
recognized as one of the largest manufacturer bidang
and exporter of small leather goods from India, manufaktur dan
has its manufacturing facility in the outskirts of mengekspor
Chennai in India. It manufactures a wide range barang-barang
of intricately designed and crafted leather kulit.
goods such as bags, wallets, belts and other
leather accessories for men and women. It's has
buyers from United Kingdom, United States and
other European countries and caters to various
buyers and brands such as -Coach, ColeHaan,
Hugo Boss, Christian Dior, Prada, M&S,
Witchery, Country Road, Trenery, J&M, Sandro,
Dragon, Isbella, and Pedro Del.
21 KALLAM SPINNING The company is engaged in cotton spinning x Perbedaan profil
MILLS LTD activities. It was founded in February of 1992 usaha.
under the name Kallam Agros Limited and was Perusahaan ini
renamed as Kallam Spinning Mills Limited in bergerak dalam
September of 1994. The company primarily kegiatan
produces cotton yarn, industrial yarns, and pemintalan
sewing threads. Its registered business office of kapas.
the company is located in Guntur, India. Perusahaan ini
terutama
memproduksi
benang katun,
benang industri,
dan benang jahit.
22 KARSU TEKSTIL The company is engaged in the production of x Perbedaan profil
SANAYI VE TICARET dyed cotton and synthetic yarns. The company, usaha.
ANONIM SIRKETI which was established by Arif Molu in 1973, Perusahaan ini
treats especially regenerated celluloid fibers, terlibat dalam
Modal, Tencel, Viscon and Blends and has produksi kapas
become internationally famous for its raw and dan benang
manufactured fabric production and marketing, sintetis.
as well as its operations in yarns. The company
is unique in Turkey and one of the leading in the
world particularly at Modal fiber treatment. The
company produces yarns of Viscon, Tencel,
Aegean cotton, Supima brand pima cotton,
organic cotton and antibacterial based amicor
fiber as well as modal, coolmax and thermolite
yarns which are uniquely produced by Karsu in
terms of product diversity. The company
produces yarns with different characteristics
based on Research&Development taking
customer demands and manufactured product
characteristics in consideration, in melange and
blend yarn technologies. The products include
ring yarns, compact yarns, open-ended yarns,

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air-jet yarns, core spun yarns, colored yarns and
twisted yarns. The company also produces
knitted fabrics, knitted yarn, linen yarn, open
end yarn, PES yarn, polyamide yarn, polyester /
cotton yarn, polyester / lycra yarn, polyester /
viscose yarn, polypropylene yarn, polywool yarn,
polywool / lycra yarn and rayon yarn. The
company produces single yarns and plied yarns
in its factory erected in Kayseri in Turkey. The
company has its registered head office located
in Kayseri, Turkey.
23 KITANIHON The company is engaged in the spinning and x Perbedaan profil

SPINNING CO., twisting of polyester and other yarns. The usaha.
LTD. company was incorporated in 1948. Kitanihon Perusahaan ini
Spinning has registered business office based in terlibat dalam
Hakusan, Japan.The company principally pemintalan dan
manufactures synthetic fiber cotton yarn and pelintiran
wool-finished yarn. Its business also includes benang poliester
streamlining and the introduction of automatic dan benang
spinning machines.In addition, the company lainnya.
operates in two business divisions: spinning and
twisting. The spinning division is engaged in the
manufacture, processing and sale of polyester
thread for applications such as car seats; while
the twisting division is engaged in the
manufacture, processing and sale of polyester
long fibers, including wool threads for knitting
and textile applications.

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24 LAKSHMI The company is a leading weaving and circular x Perbedaan profil
AUTOMATIC LOOM knitting machine manufacturer in India. It was usaha.
WORKS LIMITED incorporated in 1973 and has a registered head Perusahaan ini
office located in Coimbatore, India.The company adalah produsen
operates in two divisions: the Weaving mesin rajut
Machinery Division and the Knitting Machinery tenun dan
Division. The Weaving Machinery Division is bundar
located at Hosur in Dharmapuri District in the terkemuka.
State of Tamilnadu. The Knitting Machinery
Division is located at Singarampalayam in
Coimbatore District in Tamilnadu. Its Weaving
Machinery Division manufactures Lakshmi Ruti
'C' type high speed shuttle weaving machines,
flexible rapier weaving machines, Lakshmi
Sulzer Air Jet weaving machines, and
accessories and spares for weaving machines.
Its Knitting Machinery Division manufactures
circular knitting machines, parts and accessories
for circular knitting machines; and parts and
accessories for machine tools including work or
tool holders.
25 LAN FA TEXTILE The company is a publicly quoted company x Perbedaan profil
CO., LTD. engaged in the manufacture polyester usaha.
processing silk for weaving factories and Perusahaan ini
traders. The company was established in 1972 adalah
and is traded on the Taiwan Stock Exchange perusahaan yang
under the trading symbol 1459. It has its terdaftar secara
corporate headquarters in Taipei, Taiwan.The publik yang
company offers various products, including bergerak dalam
hygroscopic and perspiration processing silk, industri
buckskin silk, blunt-ray processing silk, superfine pengolahan
fiber processing silk, mimic muslin yarn, fat-thin polyester untuk
yarn, black-white yarn, pearl yarn, wool yarn, menenun pabrik
and ion yarn. It also manufactures functional dan pedagang.
fiber, including hygroscopic and perspiration
yarn for sport suit and golf suit; female
undergarments; shirt jacket, hat, and socks;
gloves, kneecap, and waist shield, as well as
hollow warm-keep yarn for winter clothes,
feather coats, and sport suits; anti-ultraviolet
yarn for swimming suits and ladies wear; and
difficult flammable yarn for indoor home-
bunting and decoration material for cars. In
addition, it produces superfine fiber yarn for
coat, jacket, ladies wear, leather bag, sofa
bunting, leather shoes, and wiping cloth; and
compounding fiber for skirts and trousers
material, jackets, and suits, as well as materials
for tatting and knitting. The company exports its
products to Southeast Asia, Northeast Asia and
other countries. The company has two
manufacturing facilities: Luzu factory and Zubei

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factory. The Luzu factory has 35 machines and
20 production lines, while the Zubei factory has
60 production lines. The company's quality
assurance process and standards have been set
out in accordance with ISO 9001.
26 LAP CO.,LTD. The company, with registered head office x Perbedaan profil
located in Seoul, Republic of Korea, is engaged bisnis. Selain itu,
in the manufacture of apparel, accessories and ia mendesain,
other textile products. It also produces and sells memproduksi,
trousers, work clothing and allied garments. Its dan memasarkan
products include polo and rugby shirts, t-shirt rajut
sweaters, and shorts; licensed and logoed khusus label
sportswear; casual and dress slacks; sweatshirts pribadi terutama
and T-shirts, which include turtlenecks, boxers, untuk
anoraks, and sweaters; and outerwear, hats, perusahaan
backpacks, and bags. In addition, it designs, olahraga
manufactures, and markets private label custom bermerek.
knit T-shirts primarily to branded sportswear
companies. The company sells its products to
specialty and boutique shops, upscale and
traditional department stores, mid-tier retailers
and sporting goods stores. The company offers
its products under various brands in the
domestic and international markets. It was
incorporated in 2011.
27 MEN CHUEN FIBRE The company is engaged in manufacturing x Perbedaan profil

INDUSTRY CO., textile goods. It was incorporated in January usaha.
LTD. 1987 and has its registered business office Perusahaan ini
located in Taipei City, Taiwan.The company bergerak dalam
specializes in knitting, dyeing, and finishing. It bidang
offers various types of fabric which includes manufaktur
warp knit tricot (stretch) fabrics, warp knit tricot barang-barang
(stretch) mesh, warp knit finer textured fabrics, tekstil. Ini
warp knit engineered jacquard fabrics, among menawarkan
others. The company's products are present berbagai jenis
across Taipei and in other major regions across kain yang
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Taiwan through wholesalers and other trading mencakup kain
establishments. rajut tricot
(peregangan),
rajutan lilitan
tricot
(peregangan)
mesh, lungsin
merajut kain
bertekstur halus,
kain rajut rajut
rekayasa
direkayasa.
28 NIEN HSING The company is engaged in the manufacture of x Perbedaan profil
TEXTILE CO., LTD. denim fabrics, jeans wear, and casual wear. The usaha.
company was established in 1988. The Perusahaan ini
registered head office of the company is located bergerak dalam
in Lung, Taiwan.The company aims to offer the bidang
best solution for fashion apparel. Starting from pembuatan kain
denim wears to all fashion apparel, it provides denim, jeans
the best solution to the world.In Taiwan, the wear, dan
operates production facilities in Lesotho. It also pakaian santai.
has production facilities in Nicaragua, Vietnam
and Mexico.The company offers denim fabrics
with weight from 4 to 16 ounces, such as ring
spun denim, vintage denim, herringbone denim,
long streaky, stripe denim, ramie look, crinkle
denim, honeycomb denim, befordcord, dobby
denim, stretch denim, and light to heavy weight
stretch, including cotton/Lycra,
cotton/polyester/spandex, and
cotton/nylon/spandex. It also manufactures
jeans wear with various finishing and styling
techniques, such as embroidery, patches, and
other embellishments; and also casual wear for
men and women, and boys and girls, as well as
infants.
29 NITTO BOSEKI The company is primarily engaged in the x Perbedaan profil
CO.,LTD. manufacture and sale of building materials, usaha.
fiberglass, textiles, engineering products and Perusahaan ini
specialty chemicals. Founded in 1918, it was terutama
formerly known as Fukushima Boshoku KK. Its bergerak dalam
shares are listed on the Tokyo Stock Exchange. bidang
The company's corporate headquarters is manufaktur dan
located in Tokyo, Japan.The company operates penjualan bahan
in five segments: Textiles, Building Materials, bangunan,
Glass Fiber Products, Real Estate Utilization, and fiberglass, tekstil,
Other Operations. The Textiles segment offers produk teknik
cotton spun yarn, woven stretch and knitted dan bahan kimia
stretch fabric, rayon technical yarn, anti- khusus.
bacterial treating and moisture retaining
products, knitting treated with enzymes,
interlining and other garments accessories,

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functional material, and dishcloth. The Building
Materials segment provides mineral fiber
acoustic ceiling tiles; rock wool, acoustic,
thermal insulation and fireproof panels;
fireproof covering materials; agricultural rock
wool; floor coverings, external insulation
system; fiber reinforced plastic translucent
panels; residential building materials; sealant
materials; and asbestos and dioxin removal
works. The Glass Fiber Products segment offers
glass fibers for fiber reinforced plastic and fiber
reinforced thermoplastic, glass yarn, glass
fabric, high tensile strength glass fiber, acid-
resistant glass fiber, glass products for industrial
applications, fiber reinforced plastic, and fiber
reinforced thermoplastic. The Real Estate
Utilization segment leases office buildings and
management of sports facilities. The Other
Operations segment offers clinical diagnostic
reagents in biochemistry, hematology, and
immunology; specialty chemicals, such as dye
fixative, paper making additives, metal surface
agents, and additives for inkjet paper; sound
and noise abatement systems; and soft drinks
and PET bottles.
30 OTKRYTOE The company is engaged in the manufacture of x Perbedaan profil
AKTSIONERNOE clothing and accessories. It was incorporated in usaha.
OBSHCHESTVO December of 1992 and conducts its business Perusahaan ini
PRIMORSKAYA from its registered headquarters located in bergerak dalam
SHVEINAYA FIRMA Spassk-Dalnii, Russia. The company specializes bidang
VOSTOK in producing a wide range of clothing for men, pembuatan
women and children. These products include pakaian dan
sporty tanks, sleeveless, shorts, t-shirts, aksesoris.
sweaters, blouses, suits, coats, jackets, skirts,
slacks, and evening wear dresses. Its products
are available in different styles, colors and sizes.
It also offers accessories which include gloves,
scarves, hats and bags. Its products are sold
across the domestic market through its network
of distribution sites and representatives.
31 OZERDEM The company is engaged in the weaving of x Perbedaan profil
MENSUCAT textiles. The company was incorporated in usaha.
SANAYI VE TICARET November of 2007. The registered head office of Perusahaan ini
ANONIM SIRKETI the company is located in Usak, Turkey.The terlibat dalam
company specializes in the production of woven penenunan
fabrics more than 12 inches (30.48 centimeters) tekstil.
in width. It is also produces blankets under the
Vizyon brand name. The company sells various
textile articles, including clothes, household
textiles, leather and suede, carpets, and
furniture textiles. The company also offers
knitting products, garment and clothing that

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include men’s shirt and western-style clothes
series, supplementary clothing, various
sportswear, and printing and dyeing products
such as full-cotton wool, and polyester core
yarn, khaki, poplin, twill printing, dyeing, starch,
synthetic-cotton silk, corduroy, sackcloth, and
blended textile products.
32 PETITELIN CO.,LTD. The company is an entity based in the Republic x Perbedaan profil
of Korea that is engaged in the production and usaha.
distribution of medical, dental, and hospital Perusahaan
equipment and supplies. It has its registered adalah entitas
business office located in Seoul, Korea.The yang berbasis di
company is principally involved in producing and Republik Korea
dealing medical and hospital equipment, such yang bergerak
as surgical instruments, artificial limbs, dalam bidang
operating room equipment, X-ray machines, produksi dan
hospital beds, medical and dental laboratory distribusi
equipment, professional supplies and other peralatan dan
related equipment. It also offers anesthetic persediaan
machines, vaporizers, lung ventilators, medis, gigi, dan
laryngoscopes, and other related medical rumah sakit.
products. These products and equipment are
offered to hospitals, nursing homes, general
practitioners, mortuaries, pharmaceutical
industries, and research and general
laboratories. The company has its active
operations within the country.

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33 SAE-A EINS INC. The company is engaged in the manufacture of x Perbedaan profil
cut and sew apparel. It was incorporated in usaha.
December of 2004 and conducts business in its Perusahaan ini
registered head office located in Seoul, bergerak dalam
Korea.The company is primarily involved in the bidang
following activities: manufacturing full lines of pembuatan
ready-to-wear apparel and custom apparel; pakaian potong
cutting or sewing operations on materials dan menjahit.
owned by others; performing entrepreneurial
functions involved in apparel manufacture; and
manufacturing custom garments for individual
clients. Moreover, its products include: aprons,
arm bands, athletic clothing, bathrobes, bathing
suits, coat and coat trimmings, feather-filled
clothing, jackets, handkerchiefs, hats, gloves
and mittens, lounging robes and dressing
gowns, neckties, shirts, and pants.
34 SAIBO CO.,LTD. The company is engaged in the production and x Perbedaan profil
wholesale distribution of textile products. The usaha.
company was established and incorporated in Perusahaan ini
1948. It is registered as a publicly quoted bergerak dalam
company, traded on Tokyo Stock Exchange produksi dan
under the ticker symbol 3123. The main business distribusi grosir
office of the company is located in Kawaguchi, produk tekstil.
Japan.The company has relied on all the
profitable resources and developed into a
professional manufacturer of silk quilt and other
silk bedding and clothing items. It offers the
following products made of silk: embroidery
fabric, home embroidery fabric, home printing
fabric, home woven fabric, printing fabric, and
woven fabric. In addition, the company's
products are marketed and sold in the Japan in
cooperation with its partners and affiliated
companies.
35 SEMYUNG The company is engaged in the manufacture of x Perbedaan profil
ELECTRIC electrical fittings. It was established in 1962. The usaha.
MACHINERY company is based in Busan, Republic of Korea. Perusahaan ini
CO.,LTD. The company is the leading manufacturer of bergerak dalam
warp knitting beams in the world. Its product pembuatan alat
range includes 154-, 345- and 765-kilowatt kelengkapan
transmission line fittings, optical power ground listrik.
wire (OPGW) products, spacer dampers, stock
bridge dampers, jumper spacers, hanger bands,
bands for steel crossarms, ball shackles, anchor
shackles, compression sleeves, ground clamps,
dead-end clamps and other allied products. It
also provides warp-knitting beams, which are
supplied to the textile industry, trolley wire
fittings and trolley wire equipment, forged
products and casting products. The company
also exports its products to a number of

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countries.
36 SHIKIBO LTD. The company is engaged in the manufacturing, x Perbedaan profil

processing, and marketing of textile industry usaha.
products, chemical industry products, industrial Perusahaan ini
materials, and advanced composite materials. It bergerak dalam
is also involved in real estate development bidang
which include the construction and operation of manufaktur,
shopping centers and condominiums. The pengolahan, dan
company was established in August of 1892 and pemasaran
has its registered corporate headquarters produk industri
located in Chuo-ku, Osaka.Its textile products tekstil, produk
include spun yarns, textured yarns, textile industri kimia,
material and products, knit material and bahan industri,
products, and bedding material and products. dan material
Its chemical industry products include industrial komposit
adhesive agents, and food additives. Some of lanjutan.
the company's industrial materials are dryer
fabrics for papermaking and filter cloths.

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37 SHIMA SEIKI It is a Japanese-based firm engaged in the x Perbedaan profil
MFG.,LTD. research, development, manufacture, and usaha. Ini adalah
marketing of computerized glove and flatbed perusahaan yang
knitting machines in Japan and internationally. berbasis di
It is a publicly quoted company founded in 1962 Jepang yang
and has its registered headquarters in terlibat dalam
Wakayama, Japan. The company's common penelitian,
stock is listed on the Tokyo Stock Exchange pengembangan,
under the ticker symbol 6222.The company is manufaktur, dan
known as a leader in flat knitting machine pemasaran
technology in the world. It offers a full array of sarung tangan
products including computerized flat knitting komputerisasi
machines, semi-jacquard flat knitting machine, dan mesin rajut
computer graphic apparel design systems, flatbed di Jepang
knitting CAD systems, apparel CAD/CAM dan
systems, and computerized seamless glove and internasional. Ini
sock knitting machines. The company also offers adalah
various parts for flat knitting machines and perusahaan
design systems; yarn for glove knitting publik yang
machines; and machine repair and maintenance didirikan pada
services. In addition, it is also involved in the tahun 1962 dan
operation of hotels.It offers its products to a memiliki kantor
range of industries such as textile, fashion, pusat terdaftar
broadcasting, printing, architecture, di Wakayama,
automotive, and industrial design industries. Jepang.
The company has sales and service network Perusahaan ini
throughout the world, particularly in Asia, dikenal sebagai
Americas, and Europe. pemimpin dalam
teknologi mesin
rajut datar di
dunia.
38 SHINYANG The company, with registered office located in x Perbedaan profil
CO.,LTD. Anseong-Si, Republic of Korea, is primarily usaha.
engaged in the production of cotton and other Perusahaan ini
textile fibers. It is also involved in the weaving, terutama
twisting and knitting and transforming basic bergerak dalam
cotton fibers (natural or synthetic) into yarns or produksi kapas
fabrics. These yarns or fabrics are further dan serat tekstil
manufactured into usable items, such as lainnya.
apparel, sheets towels, and textile bags for
individual or industrial consumption. The
company distributes its products in the domestic
and overseas markets. Its products include
bedclothes, mulberry wood-wool slab, pure silk
washcloth, raw silk, satin, silk cotton quilt and
silk garment. The company was incorporated in
1999.

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39 SHINYOUNG The company specializes in the manufacture x Perbedaan profil
WACOAL INC. and marketing of women's lingerie and intimate usaha.
apparel. The company was incorporated in Perusahaan ini
October 1968. It conducts business from its mengkhususkan
registered head office which is located in Seoul, diri dalam
Republic of Korea. The company offers a wide pembuatan dan
variety of foundation garments, lingerie and pemasaran
stockings, as well as fur articles. It produces lingerie wanita
bras, push up bras, girdles, slips, panties, gowns, dan pakaian
thongs, bodysuits, corsets, stockings, hosieries, intim.
pajamas and related products. It sells
underwear through department stores and
retail shops under the brand names of VENUS,
PINK VENUS, TRENO, ORLFA, ART-BEAU, CHOU
VENUS, JASMIN, OLIEN, SOLB, WACOAL,
SALUTE, MC, RIECHE, MOTHERPIA and
REMAMMA. The company operates a
manufacturing facility and research and
development (R&D) center in Seoul, Republic of
Korea.
40 SUPER SPINNING The company is engaged in the manufacture of x Perbedaan profil
MILLS LIMITED yarn in India and abroad. Its head office is usaha.
located in Tamil Nadu, India, and was Perusahaan ini
established in 1962 with an initial installed terlibat dalam
capacity of 12,000 spindles. The company is one pembuatan
of the leading textile units in Andhra Pradesh. It benang di India
manufactures 100 percent combed cotton yarn dan luar negeri.
for knitting and weaving in NE20s and NE 120s
like regular grey, ring double/TFO, compact and
elitwist, gassed, open end, core spun, slub, zero
twist. It produces cotton and synthetic knitted
garments specializing in single/double
mercerized cotton knit in polo T-shirts and
woven fabrics. It has expanded to 166,526
spindles spread over four operational units. The
company's three operational units has a total of
130,000 spindles with a spinning production
capacity of 50,000 Kg per day; weaving capacity
of 200,000 meters per month; and garment
producing capacity of 5,000 polo shirts. Its
worldwide customers include brands such as
Arrow, Aureus, Bay Hill, ColorPlus, PGA Tour,
Wilson. The company exports its products to
South Korea, Italy, Japan, United Kingdom,
United Arab Emirates, Turkey, and China.

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41 TEXRAY The company is engaged in preparing and x Perbedaan profil
INDUSTRIAL CO., spinning textile fibres. The company was usaha.
LTD. incorporated in August 1978. The registered Perusahaan ini
head office of the company is located in Shin bergerak dalam
Tien Village, Taiwan.The company specializes in mempersiapkan
the production of dyeing yarn, colored yarn, dan memintal
woven yarn, fancy yarn, woven fabric and serat-serat
apparels. It primarily offers its products to tekstil.
customers in Taiwan and internationally.
42 TOABO The company, with registered office address in x Perbedaan profil

CORPORATION Osaka, is engaged in the textile industry. It was usaha.
incorporated in the year 1922. The firm Perusahaan ini
specializes in the production and distribution of mengkhususkan
textile, interiors and industrial materials in diri dalam
Japan. It operates through three divisions: produksi dan
Clothing, Interiors and industrial materials, and distribusi tekstil,
Non textiles. In the Clothing division, the interior dan
company offers a wide range of woolen, fiber bahan-bahan
and related products. In the Interiors and industri di
industrial materials division, the company Jepang.
supplies various carpet, blankets, and fabric
products. Its Non textiles division operates with
pharmaceutical preparation and sales offices,
automobile driving school, shopping center, real
estate leasing and golf practice range. The
company operates through its more than 18
subsidiaries and six associated companies in the
country and China.
43 TOKAI SENKO K.K. The company is engaged in the printing and x Perbedaan profil
finishing of rayon and cotton textiles. It was usaha.
established in March 1941, and has its Perusahaan ini
registered head office located in Nagoya, Japan. terlibat dalam
The company's common stock is listed on the pencetakan dan
Tokyo Stock Exchange under the ticker symbol finishing rayon
3577.The company is a leading textile finisher in dan tekstil katun.
Japan. Its scope of business is centered in dyeing
cotton fabrics, synthetic fabrics and knit fabrics.
It is also active in the research and the
marketing of textiles, apparel and dyeing
equipment. The company, through its
subsidiaries, is also involved in other activities
that include: leasing of real estate; sale of
machinery, as well as the design, manufacture,
sale and repair of dyeing processing facilities
and industrial pharmaceutical analyzers;
provision of warehousing services; provision of
childcare services; and the supply of system-
related services. The company is predominantly
operating in Japan. Its products are marketed
locally and internationally.

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44 TOUNG LOONG The company is an industrial firm engaged in x Perbedaan profil

TEXTILE MFG. CO., the manufacture and wholesale distribution of usaha.
LTD. sewing threads and yarns in Taiwan and Perusahaan ini
Vietnam. It was established in the year 1960. adalah
The registered headquarters of the company is perusahaan
located in Panchiao City, Taipei Hsien. The industri yang
company is traded on the Taiwan Stock bergerak dalam
Exchange under the stock code 4401. The pembuatan dan
company specializes in the production of high distribusi grosir
technology nylon 66 air textured yarns (ATY) benang dan
and draw textured yarns (DTY) for circular benang jahit.
knitting, warp knitting, weaving for sportswear,
lingerie, hosiery and apparel, among others. Its
sewing thread products include zipper-sewing
threads, spun polyester threads, polyester
threads, nylon threads and bonded yarn sewing
threads. The company's yarn products include
label yarns, textured yarns and weaving yarns
under the brand name Supplex, Cordura,
CoolMax, Thermolite, Tactel and Lycra. It
employs approximately 911 people. The
company serves as one of the shareholders of
Chain Yarn Co., Ltd., an industrial enterprise
which was incorporated in May 1988 and is
involved in the production and marketing of
textiles, clothing and other related products.
45 TSUDAKOMA The company, with head office located in x Perbedaan profil

CORP. Ishikawa, Japan, is engaged in the usaha.
manufacturing and sale of textile machinery Perusahaan ini
and machine tool attachments. The company's bergerak dalam
operations are carried out through the following bidang
divisions: the Textile Machinery, Machine Tool, manufaktur dan
and Other Businesses divisions. The Textile penjualan mesin
Machinery division focuses in the manufacturing tekstil dan
and sale of textile machinery such as air-jet perlengkapan
looms, water-jet looms, rapier looms, alat mesin.
preparatory machinery and factory automation
(FA) systems, among others. The Machine Tool
division is involved in the manufacturing and
sale of machine tool attachments such as
indexers, numeric-control rotary tables and

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allied products. The Other Businesses division is
active in supplying electric components and cast
products, the packaging and transportation
business, and the provision of security and
recruitment services, as well as in non-life
insurance business. It was founded in March
1909 by the late Komajiro Tsuda in Ibaragi-cho,
Japan, to produce silk and artificial silk
looms.The company is the world's leading textile
machinery manufacturer. The company has five
subsidiaries and one associated company. Its
two manufacturing facilities in Japan cover a
wide range of production activities, from factory
automation with a global perspective regarding
the production environment, to computer-
integrated manufacturing. The company is
dedicated to continue taking new challenges to
bring the highest level of textile machinery to
the world.
46 VALLABH TEXTILES The company is engaged in the preparation and x Perbedaan profil
COMPANY LIMITED production of textile and clothing fibers. Its usaha.
business was established in 2008. The company Perusahaan ini
has a registered head office based in Ludhiana, terlibat dalam
India.The company specializes in the persiapan dan
manufacture and export trade of terry beach produksi serat
and face towels and bathrobes as well as other tekstil dan
kitchen linens. The company is involved in pakaian.
spinning of yarn, looms, jacquard, blended and
mixed cotton, spandex, spangle, crease and
crush as well as other fabrics and linings, such
as man-made, blended, and stretch series. The
company also offers synthetic fabrics, such as
polyester, nylon, and polyester blended fabrics
with wool, rayon, and lycra.
47 VALSON The company is engaged in the manufacture x Perbedaan profil

INDUSTRIES and sale of polyester texturized and twisted usaha.
LIMITED yarns in India. It started its operations in the Perusahaan ini
year 1983. The registered business office of the terlibat dalam
company is located in Mumbai, India. The pembuatan dan
company is principally involved in producing and penjualan
dealing cotton yarns of various counts, polyester benang
cotton yarns, polyester and staple viscose, bertekstur dan
polynosic/polyester polynosic, nylon/cotton berliku poliester.
nylon yarns, polyester wool, chenille yarns, flex
yarns/lyocell yarns, micro and spun polyester
yarns, sewing thread yarns, embroidery bright
yarns, and tencil yarns/modal yarns, as well as
air texturized yarns for automotive industry. It
also provides cotton, spun, viscose, and chenile
dyeing services. Its products are used in

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upholstery, suiting and shirting, sarees, home
furnishings, labels, luggage, knitting, dress
materials, and automatic fabrics. The company
also exports its products to the Middle East, the
United Kingdom, Egypt, Mexico, and other
European markets.
48 WOOYANG The company is engaged in the manufacture x Perbedaan profil

CO.,LTD. and sale of cut and sew apparel. It was usaha.
incorporated in November of 1992 and it Perusahaan ini
conducts business from its registered head terlibat dalam
office located in Busan, Republic of Korea.The pembuatan dan
company is primarily involved in the following penjualan
activities: manufacturing full lines of ready-to- potong dan
wear apparel and custom apparel; cutting or menjahit
sewing operations on materials owned by pakaian.
others; performing entrepreneurial functions
involved in apparel manufacture; and
manufacturing custom garments for individual
clients. Moreover, the company's products
include: aprons, arm bands, athletic clothing,
bathrobes, bathing suits, coat and coat
trimmings, feather-filled clothing, jackets,
handkerchiefs, hats, gloves and mittens,
lounging robes and dressing gowns, neckties,
shirts, and pants.
49 YI JINN The company is engaged in the manufacture x Perbedaan profil

INDUSTRIAL CO., and sale of textured yarns, polyester yarns and usaha.
LTD. woven fabrics. It was founded in 1981 and has Perusahaan ini
its registered head office in Taipei, Taiwan. The terlibat dalam
company markets its products under the brand pembuatan dan
name Sea Gull. The company offers various penjualan
types of yarn which include, air intermingle, benang
wooly yarn, setting yarn, non-torque, dope dyed bertekstur,
black, linen-like yarn, and nylon stretch yarn. benang poliester
These products are used in weaving assorted dan kain
suits, jacks and trousers, and shirts for men and tenunan.
women. Its major product is textured polyester
yarn, which is used for the manufacture of flat
and knitting fabrics, as well as zipper ribbons.
The company sells its products in the domestic
market and overseas markets, such as Asia,
Europe, and the Americas. The company also
has corporate partners that include Hangzhou Yi
Jinn Textile Co., Ltd., Yi Tong Fiber Co., Ltd.,
Triple Circle Corporation, Shangtex Industrial
Co., Ltd., Chu Sing Industrial Co., Ltd., and
Cheering Knitting Industrial Co., Ltd.

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50 ZAKRYTOE The company is an entity engaged in the x Perbedaan profil

AKTSIONERNOE manufacture of textiles. The company is also usaha.
OBSHCHESTVO involved in preparing and spinning textile fibres. Perusahaan
FIRMA GIGIENA The company was incorporated in April of 2000. adalah entitas
The registered head office of the company is yang terlibat
located in Ekaterinburg, Russia. The company dalam
specializes in weaving, knitting, crocheting, or pembuatan
bonding fibres. Its textiles are used for clothing tekstil.
and containers such as bags and baskets. The
company operates a production facility in
Ekaterinburg, Russia. The company is also a
producer of acetate and acrylic yarn, made from
purchased staple; carded, carpet, and combed;
crochet yarn; and cotton, silk, and manmade
staple. It primarily offers its products to
customers in Russia.
51 ZHANGZHOU The company is engaged in operating fiber, x Perbedaan profil

WEIHAO yarn, and thread mills. It was incorporated in usaha.
CHEMICAL FIBER the year 2005 and conducts business from its Perusahaan ini
CO., LTD. registered corporate office which is strategically bergerak dalam
located in Zhangzhou, China. The company's pengoperasian
business operation specializes in spinning yarn, pabrik serat,
manufacturing thread of any fiber, texturizing, benang, dan
twisting, and winding purchased yarn or benang.
manmade fiber filaments, and producing hemp
yarn and further processing into rope or bags. It
also conducts preparation of fibers, weaving of
fabric, knitting of fabric, fabric finishing, and
fabricating fabric products as well as offers
basic alterations, such as hemming, taking in or
letting out of fabrics, and lengthening or
shortening services.

Page 94
B. Informasi Profil Usaha Perusahaan Pembanding Final
Perusahaan Pembanding Diterima
Nama
No. Nomor BvD ID Gambaran Usaha
Perusahaan
1 BANDO INC KR1101111839103 This company was formerly known as Ktol Co Ltd. It is
CO.,LTD. engaged in the manufacture of wearing apparel and clothing
accessories. It was incorporated in the year of 1999 and
conducts business in its registered head office located in
Seoul, district of Gangnam-gu, Korea. The company produces
a wide range of apparel and clothing for men, women and
children of all ages. Its products include: shirts, blouses, coats
and jackets, vests, skirts, jeans, casual and formal dresses,
gowns, shorts, underwear, suits, tuxedos as well as belts,
wallets and pouches, shawls, scarves, socks and stockings,
shades, caps and hats.
2 BANNU PK30071FP The company is engaged in the manufacture and sale of
WOOLLEN MILLS woolen yarn, cloth, and blankets primarily in Pakistan. It was
LIMITED established in the year 1953 and conducts business in its
registered head office located in Kohat, Pakistan. The
company's products include woollen wear for men and ladies,
woollen cloth, services uniform cloth, woollen blankets,
shawls, upholstery/curtain cloth and acrylic blankets, and
light winter wear. It markets its products through a network
of dealers, as well as directly and to government, semi
government agencies, and institutions.
3 BINHAI SALES CN9360024299 The company is primarily engaged in the manufacture and
CO., LTD. supply of cut and sew apparel. It is involved in manufacturing
and marketing cut and sew apparel from woven fabric and
purchased knit fabric. It was incorporated in June of 2006.
The company has a registered office located in Yancheng in
Jiangsu, China.The company consists of a diverse range of
establishments manufacturing full lines of ready-to-wear
apparel and custom apparel: apparel contractors (performing
cutting or sewing operations on materials owned by others),
jobbers (performing entrepreneurial functions involved in
apparel manufacture), and tailors (manufacturing custom
garments for individual clients). The company operates
principally in the People's Republic of China.
4 CARNIVAL TW11825825 The company is a publicly quoted entity that is engaged in the
INDUSTRIAL manufacture of textile products. It was established in 1969 as
CORPORATION Carnival Textile Industrial Corp and changed its name to
Carnival Industrial Corporation in 1997, and has its registered
head office strategically located in Taipei, Taiwan.The
company specializes in the manufacturing and selling of
apparel and other fabrics as well as supply of dyeing and
printing services in Taiwan. It offers a selection of suits for
men and women under its own brand names, Carnival and
Profilo Uomo. In addition to suits, the company supplies other
related products such as footwear, stockings, men's socks,
children's socks, underwear, and swimsuits for women, as
well as home wear suits, knit sweaters, casual shirts, pants,
and short leather jackets for men. It exports its products

Page 95
Nama
Perusahaan
primarily to Europe, Asia, and the United States.
5 COMME DE KR1101113043942 The company, incorporated in 2004, is engaged in

GAMME manufacturing work clothing and allied garments, and
CO.,LTD. furnishings. Its registered head office is strategically located
in Seoul, Republic Of Korea. The company is involved the
production of cut and sew apparel from woven fabric or
purchased knit fabric including men's and boys' suits, coats
and overcoats. It also manufactures full lines of ready-to-
wear apparel and custom apparel, and manufacture custom
garments for individual clients. In addition, it performs
cutting or sewing operations on materials owned by others,
entrepreneurial functions involved in apparel manufacture,
and weaving or knitting fabric. The company also employs
staff knowledgeable in fashion trends and the proper match
of styles, colors, and combinations of clothing and accessories
to the characteristics and tastes of the customer.
6 ECLAT TEXTILE TW35884479 The company is a publicly quoted entity that is engaged in the
CO., LTD. manufacture of textile products. It was incorporated in 1977
and has its registered head office located in Taipei, Taiwan.
The company's common shares are listed on the Taiwan Stock
Exchange under the ticker symbol 1476.The company is
considered as the largest circular knitter in Taiwan. It is also a
vertical producer of circular knit fabrics for the high
performance activewear, intimated apparel, swimwear, and
casual sportswear markets. It manufactures all types of
knitted fabrics, including single knit jersey, interlock, rib knit,
jacquard, terry knit, and fleece. In addition, it provides
apparel under Eclon, Eclat, and Body Care brands.The
company aims to develop functioned fabrics and research
fabric and apparel that convey the pursuit of esthetically
healthy trends. The company has operations in Asia and the
Americas. It manufactures its products in Taiwan, Mainland
China, the United States and Vietnam. The company's
customers are major leading labels, department stores, chain
stores, manufacturers, and importers from around the world.
7 KALIM KR1101110707020 The company is engaged in manufacturing work clothing and
COMPANY allied garments, and furnishings. It was incorporated in 1990
CO.,LTD. and has its registered head office strategically located in
Seoul, Republic Of Korea. The company is involved the
production of cut and sew apparel from woven fabric or
purchased knit fabric including men's and boys' suits, coats
and overcoats. It also manufactures full lines of ready-to-
wear apparel and custom apparel, and manufacture custom
garments for individual clients. In addition, it performs
cutting or sewing operations on materials owned by others,

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Perusahaan
entrepreneurial functions involved in apparel manufacture,
and weaving or knitting fabric. The company also employs
staff knowledgeable in fashion trends and the proper match
of styles, colors, and combinations of clothing and accessories
to the characteristics and tastes of the customer.
8 KNF KR1101114448274 The company is primarily engaged in the manufacture of

INTERNATIONAL work clothing products. The company specializes in
CO.,LTD. manufacturing washable service apparel, laboratory coats,
work shirts, work pants, and hospital apparel. The company
was incorporated in October of 2010. The registered head
office of the company is located in Seoul, Republic of Korea.
9 KOCH KR1101114126127 The company is a Republic of Korea based enterprise engaged

INTERNATIONAL in the manufacture and distribution of men's and boys'
CO.,LTD. clothing and other related products. It operates its business
primarily in the domestic market. The company was
incorporated in the year 2009. Its registered business office is
based in Seoul, Republic of Korea. It is registered as a limited
company.The company's business activities include the
manufacture and distribution of a general line of new men's
and boys' clothing and furnishing, such as men's and boys' cut
and sew suit, coat, and overcoat. It is also involved in the
provision of basic alterations, such as hemming, taking in and
letting out seams, and lengthening and shortening sleeves.
10 MAKALOT TW23609668 The company is engaged in the manufacture, processing and
INDUSTRIAL CO., wholesale of apparels for the American and European
LTD. markets. It was established in January of 1990 and is traded
on the Taiwan Stock Exchange under the stock code 1477.
The company is headquartered in Taipei, Taiwan. The
company provides original equipment manufacturer (OEM)
and original design manufacturer (ODM) services of
garments, including knitting and weaving products, such as
underwear, pajamas, skirts, dresses, tops, jackets, trousers
and sportswear, among others. It produces approximately
2,500 styles across more than 15 categories, and guarantees
to satisfy all its clients' needs. Also, it offers services, such as
global logistics, business marketing, design and development,
manufacturing, and trend analyzing. The company has
operations in eight countries, including France, China,
Indonesia, Philippines, United States, and Cambodia. Its
major market is in the United States. The major clients of the
company include leading ready-to-wear apparel retailers in
the United States, such as Wal-Mart, GAP, and Target. Its
customers include Macy's, Mervyns, Ann Taylor, JCPenny, Old
Navy, Hanes Brand Inc., K Mart, Abercrombie&Fitch, Carter's,
Express, and Federated. The company aims to become a

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world-class apparel supplier for leading garment channels by
developing mid-priced, fashionable, and diversified products.
It has its factories in Shanghai (China), Manila (Philippines),
Jakarta (Indonesia), Duong province (Vietnam), Sri Lanka, and
Pnom Penh (Cambodia).
11 MONTE CARLO IN101389FI The company is engaged in the manufacture, marketing and
FASHIONS wholesale of textiles, clothing and footwear for men and
LIMITED women. Its business was incorporated in July of 2008. The
company has a registered head office based in Ludhiana,
India.The company offers products include sneakers, boots
and Shoes, T shirts, jeans, snapbacks and fitted hats, shorts,
button-down shirts, hoodies, jackets, outerwear, polos,
dresses, bags, jumpsuits, high heels, leather jackets, skinny
jeans, cargo pants, button down shirts, sweater vests, denim
jeans, sandals, casual clothes, outdoor footwear, baseball
caps, knit leggings, and fashion clothing.
12 NISHIMATSUYA JP000030983JPN The company is engaged in the manufacture and sale of
CHAIN CO.,LTD. children's and infants' outerwear. It was incorporated in the
year 1956. The registered head office of the company is
located in Himeji, Japan.The company is primarily involved in
manufacturing children's and infants' outerwear, from
purchased woven or knit fabrics. It principally conducts its
business operations within the country.
13 NOBLE KR1101112149014 The company is engaged in the manufacture of knitted and
INDUSTRY crocheted apparel. It was incorporated in January of 2001.
CO.,LTD. The registered business office of the company is located in
Seoul, Republic of Korea.The company offers a wide range of
products such as trousers, dresses, shorts, knitted and
crocheted pullovers, and cardigans. It also provides shirts,
tops, skirts, as well as pants, and other related products.The
company is active and operational in the Republic of Korea.
14 PEPLOS RU05271134 The company is engaged in the manufacture and sale of

knitted and crocheted apparel in the Russian Federation.
Incorporated in December 1992 and has its registered
business office located in Chebarkul, Russian Federation.The
company offers a wide range of products such as trousers,
dresses, shorts, knitted and crocheted pullovers, and
cardigans. It also provides shirts, tops, skirts, as well as pants,
and other related products. The company is active and
operational mainly in the Russian Federation.

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15 SEONG AN KR1701110006868 The company is engaged in the manufacture of textile
CO.,LTD. products. It was incorporated in April of 1976. The registered
business office of the company is located in Daegu, Republic
of Korea.The company produces three main products:
polyester woven fabrics, blended fabrics and knit fabrics.The
polyester woven fabrics include sizing fabrics, spandex,
melange fabrics, twist fabrics and stretch fabrics.The blended
fabrics are composed of suede, nylon, cotton spandex and
polyester plain.The knit fabrics consist of span velvet, fur
bonded with suede, matt jersey, single span, nylon metallic
and micro velboa fabrics.The company is active and
operational in the Republic of Korea.
16 SU KR1101110946438 This company is engaged in the manufacture of wearing

INTERNATIONAL apparel and clothing accessories. It was incorporated in the
CO.,LTD. year of 1993 and its registered business office is located in
Seoul, district of Songpa-gu, Republic of Korea. The company
produces a wide range of apparel and clothing for men,
women and children of all ages. Its products include: shirts,
blouses, coats and jackets, vests, skirts, jeans, casual and
formal dresses, gowns, shorts, underwear, suits, tuxedos as
well as belts, wallets and pouches, shawls, scarves, socks and
stockings, shades, caps and hats.
17 SUHYANG KR1101110755350 The company is engaged in the manufacture of clothing and

NETWORKS accessories in the Republic of Korea. It was incorporated in
CO.,LTD. the year 1991 and conducts its business from its registered
head office located in Seoul. The company specializes in
producing a wide range of men's and women's clothing,
which include sporty tanks, sleeveless, shorts, t-shirts,
sweaters, blouses, suits, coats, jackets, skirts, slacks, and
evening wear dresses. It also offers accessories which ranges
gloves, scarves, hats and bags. The company primarily
operates in Korea.
18 THE WILLBES & KR1101110172447 This company, formerly known as Kunja Idustrial Co., Ltd.,
CO.,LTD. operates as an original equipment manufacturer (OEM) of
textiles. It was founded in 1973, and has its registered head
office in the city of Cheonan-si in the Republic of Korea. The
company operates through three divisions: Global, Education
and Investment. The Fiber Division is active in providing
woven products, knits, sweaters, microfibers and others,
through its oversea subsidiaries. The Education Division is
active in providing education services to various individuals,
such as government officials, lawyers, diplomats, appraisers,
labor attorneys and others. The Investment Division is active
in administering the local areas as well as overseas affiliates
and corporations, and in exploring new profitable businesses.
The company's clients include TARGET, OLD NAVY and WAL
MART. Its products are marketed and sold throughout Korea
and internationally in cooperation with its local and foreign
business partners and affiliates.

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19 WORLVI KR1101112409616 The company is a designer, manufacturer and seller of men's
TRADING and women's clothing and apparel accessories, under the
CO.,LTD. brand Evisu. Its products include jeans, tees, shirts, sweats,
and knits for men and women. It also offers kids categories,
as well as shoes, accessories, and sunglasses for men. In
addition, it provides online sale of selected goods. The
company was incorporated in December of 2001 and has its
registered head office strategically located in Seoul, South
Korea.

Page 100
Attachment D - Financial Information of Final Comparison Company
Average 3 years 2015 2014 2013

Company
No Gross Gross
Name NCP Revenue Gross Profit Revenue Revenue Revenue Gross Profit
Profit Profit
1 BANDO INC 7,99% 18.383.088 1.359.735 18.205.543 1.333.049 20.059.129 1.314.473 16.884.593 1.431.685
CO.,LTD.
2 BANNU 14,61% 7.727.729 985.253 7.346.621 950.718 7.843.569 1.030.067 7.992.997 974.974
WOOLLEN
MILLS LIMITED
3 BINHAI SALES 6,35% 65.610.157 3.916.264 21.118.847 -44.520 25.142.181 210.655 150.569.443 11.582.656
CO., LTD.
4 CARNIVAL -1,42% 63.732.570 -920.855 64.529.038 -1.224.771 59.979.815 78.238 66.688.858 -1.616.033
INDUSTRIAL
CORPORATION
5 COMME DE 6,42% 13.576.235 819.355 13.193.177 1.188.913 16.628.764 877.831 10.906.765 391.321
GAMME
CO.,LTD.
6 ECLAT TEXTILE 21,85% 678.138.493 121.591.901 773.970.766 145.783.515 657.124.841 114.789.944 603.319.872 104.202.243
CO., LTD.
7 KALIM -5,24% 1.377.960 -76.229 808.766 -460.902 1.199.854 -1.819 2.125.261 234.034
COMPANY
CO.,LTD.
8 KNF 6,50% 40.990.946 2.501.969 42.576.545 2.446.908 45.666.333 2.590.740 34.729.959 2.468.258
INTERNATIONL
AL CO.,LTD.
9 KOCH 10,66% 19.327.798 1.861.348 24.715.564 2.848.614 18.727.372 1.845.720 14.540.458 889.710
INTERNATIONA
L CO.,LTD.
10 MAKALOT 10,88% 644.552.940 63.258.830 691.420.428 75.083.259 648.598.172 61.387.881 593.640.219 53.305.349
INDUSTRIAL
CO., LTD.
11 MONTE CARLO 18,25% 90.413.999 13.954.472 93.836.063 13.947.602 93.523.990 14.854.724 83.881.943 13.061.089
FASHIONS

Page 101
LIMITED
12 NISHIMATSUYA 4,44% 1.167.681.880 49.657.128 1.171.164.048 52.116.403 1.077.695.7 44.541.337 1.254.185.840 52.313.644
CHAIN CO.,LTD. 54
13 NOBLE 9,39% 35.934.990 3.083.582 40.890.404 3.255.437 34.905.849 2.905.485 32.008.716 3.089.824
INDUSTRY
CO.,LTD.
14 PEPLOS 1,99% 9.192.678 179.616 6.496.946 418.000 7.478.617 110.917 13.602.471 9.930
15 SEONG AN -1,57% 59.437.270 -946.803 44.556.075 -511.727 61.712.908 -2.945.511 72.042.826 616.828
CO.,LTD.
16 SU 9,74% 39.707.055 3.523.177 42.608.954 4.562.047 40.934.231 3.615.028 35.577.979 2.392.458
INTERNATIONA
L CO.,LTD.
17 SUHYANG 4,53% 150.327.331 6.508.995 157.503.620 7.081.450 148.312.563 6.354.953 145.165.810 6.090.582
NETWORKS
CO.,LTD.
18 THE WILLBES & 1,30% 214.919.912 2.766.996 239.481.442 -1.920.682 204.380.060 3.759.665 200.898.233 6.462.005
CO.,LTD.
19 WORLVI -2,24% 17.159.960 -393.762 12.755.650 -960.341 17.139.998 -906.941 21.584.233 685.996
TRADING
CO.,LTD.

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Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 0

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 1

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 2

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 3

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 4

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 5

1.1 Document Purpose

1.2 The Scope of Document

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 6

We believe that our recommendations will reflect a reasonable interpretation of

If there are changes in Transfer Pricing regulations in jurisdictions or relevant market

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 7

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 8

1.5 Group Overview

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 9

Table 2 - Ownership Percentage for 2017

1.6 Controlled Transactions Checked

Table 3 - Companies Related to Book Year Affiliate Transactions

2. Trade Nobland The Korea Companies 51.528.034.135 Receivable from

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 10

4. Current Nobland Korea Companies 78.674.997 Current Liability

1.7 Characteristics of Business

1.8 The Most Appropriate Transfer Pricing Method

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 11

The following table shows the PLI used.

Table 4 - Selected Profit Level Indicator

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 12

Table 5 - Calculation of TNMM with Profit Level Indicator

WA NCP NCP NCP NCP

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 13

Mr. Kwon Ogeun Commissioner

No. Company Name Number of Shareholder Number of

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 14

2.2.3 CDB Organizational Structure

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 15

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 16

Local Document PT Cipta Dwi Busana Fiscal Year 2017 Page 17

Local Document PT Cipta Dwi Busana Fiscal Year 2017

Local Document PT Cipta Dwi Busana Fiscal Year 2017

Local Document PT Cipta Dwi Busana Fiscal Year 2017

2.2.4.1 Quality Control Procedure in CDB

Local Document PT Cipta Dwi Busana Fiscal Year 2017

Local Document PT Cipta Dwi Busana Fiscal Year 2017

a. Quality Control (QC) Raw Materials and Accessories in the Warehouse

Local Document PT Cipta Dwi Busana Fiscal Year 2017

2.2.5 CDB Product Description

Local Document PT Cipta Dwi Busana Fiscal Year 2017

Local Document PT Cipta Dwi Busana Fiscal Year 2017

FIgure 4 - CDB Group Shareholders

99,75% 99% 100% 100% 100% 100% 100%

Indonesia Vietnam Amerika China

3.2 Transfer Pricings

3.3 Affiliated Parties

Local Document PT Cipta Dwi Busana Fiscal Year 2017

3.3.2 Receivable Transactions from Affiliates

Receivables with a value of Rp. 51,528,034,135 is a transaction of receivables from

3.3.3 Debt Transactions to Affiliated Parties

No Company name Country Value Transaction

Local Document PT Cipta Dwi Busana Fiscal Year 2017

Local Document PT Cipta Dwi Busana Fiscal Year 2017

Local Document PT Cipta Dwi Busana Fiscal Year 2017