Analisis proses pembuktian kewajaran pembebanan royalti antar pihak yang memiliki hubungan istimewa : studi kasus PT L tahun pajak 2011

Deskripsi

This internship report discusses about the processes of proving the arm?s length principle upon the charge of royalty expense with two different types of agreement which carried out by PT L with its related parties. With this two different agreements, a comparable search transaction by type is required to test the arm?s length condition of the transaction. The method used to test the reasonableness of the royalti transaction is the Comparable Uncontrolled Price (CUP) method. The processes in proving the arm?s length condition are based on the regulation of taxation in Indonesia, PER-43/PJ/2010 as lastly amended with PER-32/PJ/2011..