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Analisis sengketa transfer pricing atas transaksi ekspor PT "X" : studi kasus pada PT "X" di Jakarta
The economic globalization has raised a new interesting phenomenon, which is the integration of national economies. Market liberalization, money flow and technological transfer has push the world economy in becoming more open and ignore boundary between countries that causing no country has no connection and no economical dependence. This can be seen by the dramatic increasement of multinational enterprises role in world trade. Almost all transaction and economic activities happen within group of multinasional enterprises. The transaction covers goods, services, technology or loan. Because of the existance of dependent transaction, an appropriate transfer prices calculation based on transfer pricing policy is needed. The transfer price manipulation is the action of the firm to exchange goods or services within its organization at a price different from that at which it would trade those goods and services to an independent firm. Corporate intentionally doing the multinational transfer pricing practice in order to shift profit from one country to another country with lower tax rate (tax heaven countries), which can cause tax distortion. In dealing with transfer pricing dispute between tax payers and tax administrators, OECD applied the arm?s length principal which can eliminate distortion in tax load. There are several methods that are used to apply the arm?s length principle, First, Traditional method, that consists of (1) Comparable Uncontrolled Price Method (CUPM), (2) Resale Price Method (RPM), and (3) Cost Plus Method (CPM). The second method is Transactional Profit Method, that consists of (a) Profit Split Method, and (b) Transactional Net Margin Method (TNMM). The third method is Global Formulary Apportionment. In dealing with transfer pricing matters and in accordance with the development of international taxation, Section 18 of Goverment regulation Number 17 year 2000 about Income taxes give authority to Directorate general of tax to: (1) redetermine the amount of income and reduction and also determine obligation as capital in counting the ammount of taxable income for dependent tax payer. (2) Determine transaction price among related parties. (3) Determine conditions that can raise a dependent relationship. Inspite of the regulation above, Directorate General of Tax also issued Kep-01/PJ.7/1993 date March 9th 1993 about tax examination guidelines for dependent tax payer, and SE-04/PJ.7/1993 date March 9th 1993 as a guidelines in handling transfer pricing cases in order to prevent transfer pricing manipulation that can cause tax revenue loss. Ada bibliografi & tabel
Ketersediaan
| Call Number | Location | Available |
|---|---|---|
| T 699/05 | PSB lt.2 - Karya Akhir | 1 |
| Penerbit | Jakarta Magister Akuntansi FEUI., 2005 |
|---|---|
| Edisi | - |
| Subjek | Taxation Pharmaceutical industry Transfer pricing Exports |
| ISBN/ISSN | - |
| Klasifikasi | - |
| Deskripsi Fisik | xiii, 126 p., 14 p. : diagr. ; 28 cm & lamp |
| Info Detail Spesifik | - |
| Other Version/Related | Tidak tersedia versi lain |
| Lampiran Berkas | Tidak Ada Data |