Laporan International Summit Scientific Research Congress

Valdemar, Renfred and Widyaning, Merrie and Samarda, Elissa and Gultom, Jerri and Khifni, Mokhamad and Saragi, Herbin (2024) Laporan International Summit Scientific Research Congress. In: The International Trade and Economic Congress, 10 Mei 2024, Turkiye.

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Abstract

Transfer Pricing is a policy regulated by company to determine the transfer price for a transaction, whether the price of goods, services, intangible assets, or financial transactions carried out by the Company both domestically and internationally. In practice, there are many tax disputes over transfer pricing transactions, especially in affiliated trading companies. Companies often appeal to the Tax Court against decisions issued by the Tax Office. The results of decision on appeal also varied, thus causing to injustice and legal uncertainty for the Company as a taxpayer. So, in this case, it is important to analyze Tax Regulations and Tax Court Decisions which greatly contribute to the tax environment in Indonesia. This research analyzes the legal framework that regulates transfer pricing in Indonesia with a focus on efforts to increase taxpayer obedience and reduce appeal disputes. The method used in this research is normative juridical method and study of tax court literature by collecting and analyzing secondary data such as regulations, determinations and tax court decisions to reveal the complexity of transfer pricing disputes. This research also explores the mechanism of Advance Pricing Agreement (APA) and the Mutual Agreement Procedure (MAP). This research aims to provide recommendations and make a significant contribution to taxpayers regarding the importance of a deep understanding of tax law regulations and efforts to increase compliance and fairness in the taxation system in Indonesia. To realize tax environment development in Indonesia to be more transparent, fair and sustainable. Keywords: Transfer Pricing, Taxpayer Compliance, Tax Court

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