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Analisis Kualitas Informasi Dokumentasi terkait Benefit Test pada Transaksi Transfer Pricing Intra-Group Services untuk Memenuhi Arm’s Length Principle
Intra-group transaction of services between affiliated companies is one of the transactions that has a high transfer pricing risk. This research is motivated by a dispute between taxpayers and the tax authorities in Indonesia (Directorate General of Taxes -DGT) related to testing the economic benefits of intra-group service transactions. The benefit test is one of the requirements that must be met by the taxpayer in order to fulfill the arm's length principle. Taxpayers must prove the existence of economic benefits that can add value to the provision of these services. The purpose of this study is to analyze the quality of information of transfer pricing documentation related to the benefits of intra-group transaction services in order to meet the arm's length principle, and identify the ideal quality of information that should be presented in the document. The researcher conducted a content analysis of the summary of information related to the intra-group service benefit test in 147 taxpayer transfer pricing documentation for the period 2017 to 2019, by comparing them with the regulations in Indonesia. Furthermore, the researcher confirmed the findings of the content analysis to the Tax Authorities and Tax Consultants through the interview process. The results of this study indicate that most of documentation in this study does not explain in detail about testing the benefits of intra-group services. Transfer pricing documentation should be described in detail so that can minimize information asymmetry between the authority and the taxpayer and also reduce the risk of disputes. This study has implication that the taxpayers need to provide adequate documentation in testing the economic benefits of intra-group services to reduce tax disputes. For regulators, this research has implications for clarifying benefit testing in transfer pricing documentation reports and the concept of economic benefits.
Call Number | Location | Available |
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T 041/21 | PSB lt.2 - Karya Akhir | 1 |
Penerbit | Jakarta Program Studi Magister Akuntansi Fakultas Ekonomi dan Bisnis Universitas Indonesia., 2021 |
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Edisi | - |
Subjek | Transfer pricing Benefit test Arm's length principle |
ISBN/ISSN | - |
Klasifikasi | NONE |
Deskripsi Fisik | xii, 69 p. ; diagr. ; 30 cm |
Info Detail Spesifik | - |
Other Version/Related | Tidak tersedia versi lain |
Lampiran Berkas | Tidak Ada Data |