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Praktik Perpajakan Transfer Pricing Intensive Advertising, Marketing and Promotion Expense di Indonesia (studi kasus PT Z)
This study aims to analyze problem that arise in determining marketing intangibles of advertising, marketing and promotion expense (AMP expense) by distributors whose brand of the products are owned by affiliates and determine arm’s length principle of AMP expense based on the provisions and concepts of transfer pricing. The concept used in this study are OECD (2017) and tax regulations that apply in Indonesia. This research uses a qualitative approach with a case study at PT Z. The results show that the indicator that can be used to determine the emergence of marketing intangibles from transfer pricing AMP expenses of affiliated companies is the amount of AMP expense that exceeds the amount of AMP expense from the comparison company according to the results of interviews with the tax authorities. and academics. The results of the interview are used because there are no tax provisions that can provide guidance in identifying AMP expenses that can cause marketing intangibles. Ownership of marketing intangibles is carried out through an functions, assets, and risks analysis that focus on the development, improvement, maintenance, protection, and exploitation (DEMPE) of marketing intangibles (OECD, 2017). Remuneration for marketing intangibles can be given in the form of a reduction in the purchase price, direct compensation for expenses that exceed the expenses of independent parties plus profits based on the functions and risks borne (OECD, 2017). Arm’s length principle of AMP expense transfer pricing transactions in this study can be used by research object to reduce audit risk.
Call Number | Location | Available |
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T 039/21 | 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 Tax Arm's length principle |
ISBN/ISSN | - |
Klasifikasi | NONE |
Deskripsi Fisik | xiii, 57 p. ; diagr. ; 30 cm |
Info Detail Spesifik | - |
Other Version/Related | Tidak tersedia versi lain |
Lampiran Berkas | Tidak Ada Data |