<![CDATA[The practice of underinvoicing crude palm oil (CPO) exports through misdeclarations of fatty matter and palm oil mill effluent (POME) is nothing less than a form of tax evasion that exploits loopholes in tax and customs regulations. This practice is no longer carried out solely through the manipulation of nominal prices on invoices but has evolved into the manipulation of commodity quality and classification to obtain an export reference price lower than the actual economic value. This study employs a normative method based on an analysis of laws and regulations and is supported by a literature review covering books, scientific journals, and various other relevant sources. In addition, a qualitative approach was applied using descriptive analysis techniques structured through inductive reasoning. The research results indicate that the misdeclaration of “Fatty Matter” and “POME” can be classified as a form of hidden underinvoicing that substantively meets the elements of tax evasion because it involves active manipulation of material data, resulting in a reduction in government revenue. This study also found that the main obstacles to oversight lie in the weak integration between the Directorate General of Taxes and the Directorate General of Customs and Excise, the fragmentation of databases, and the suboptimal technical verification of CPO quality. A re-conceptualization of fiscal oversight through the strengthening of the General Anti-Avoidance Rule (GAAR), real-time data exchange integration, independent laboratory verification, and the use of data analytics and risk-based audits is crucial to closing underinvoicing loopholes and strengthening fiscal justice in international trade]]>
