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Perilaku Perusahaan Multinasional dan Aggressive Transfer Pricing Practices Terhadap Kepatuhan Pembebanan Biaya Promosi (Studi Kasus Kasus PT MSM) Supriyadi Supriyadi
Majalah Ilmiah Bijak Vol 16, No 2: September 2019
Publisher : Institut Ilmu Sosial dan Manajemen STIAMI

This research aimed to analyze Multinational Enterprises behavior and aggressive transfer pricing practices that compliance of promotion expenses (Case Study PT MSM). First, to analyze formal compliance of promotion expenses on MNEs. Second, to analyze material compliance of promotion expense on MNEs. Third, to analyze economic benefits for PT MSM and MNEs.The research approach used is descriptive qualitative with data collection through in-depth interviews with informations determinded by Account Representative of the Tax Sercive Office B that handles PT MSM. The research instrument is the data and information collection through interview dan documentation. This reseach is used MNEs theory and compliance theory.The research results show that: first, promotion expenses on MNEs that Case Study PT MSM reach about Rp 3,2triliun from fiscal year about 2003 until 2016 average 20% form sales. For formal compliance analysis for promotion expenses for PT MSM is comply with Ministry of Finance Regulation number 02/PMK.03/2010 about promotion expenses with attaching nominative list of promotion expenses. Second, for material compliance analysis of promotion expenses is not directly related for PT MSM, to promote MNEs. Third, promotion expenses that paying PT MSM gives economic benefit for promotion of MNEs. Therefore PT MSM should get renumeration because of its function, assets and risks.

AUTOMATIC EXCHANGE OF INFORMATION SEBAGAI SARANA MENINGKATKAN EMPAT PILAR KEPATUHAN PAJAK Supriyadi Supriyadi
Jurnal Reformasi Administrasi : Jurnal Ilmiah untuk Mewujudkan Masyarakat Madani Vol 6, No 2: September 2019
Publisher : Institut Ilmu Sosial dan Manajemen STIAMI

The Government of Indonesia carr out extra efforts program to increase tax compliance and to explore potential tax revenues, one of which is through the use of Automatic Exchange of Information (AEoI). This aims of this study are to analyze the utilization of AEoI in order to increase tax compliance; to analyze AEoI to explore potential tax revenue; and to analyze the barrier of using AEoI in an effort to increase the four pillars of tax compliance. The four pillars of tax compliance include registration, payment, reporting and payment of tax arrears. This research is qualitative in nature by using the literature study method through combining several literature related to national and global implications of AEoI using secondary data. The entire data is collected by using data collection methods (library research). The results of the study indicate that the Directorate General of Taxes has not utilized the AEoI data to improve the four pillars of tax compliance. AEoI Data Management is still at the stage in the process of registration, reporting and change. The factors that inhibited the use of AEoI were that Directorat General of Taxes (DGT) was still in the process of preparing the operating standards and procedures for the use of AEoI and the establishment of a Directorate of Data and Information. Besides that, socialization to the vertical units of DGT and taxpayers is still limited.

Apakah Transfer Pricing Documentation Meningkatkan Kepatuhan Pajak? - Supriyadi Sukarno
Jurnal Pajak dan Keuangan Negara (PKN) Vol 4 No 1S (2022): Sigap Hadapi Tantangan, Tangguh Kawal Pemulihan
Publisher : Politeknik Keuangan Negara STAN

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.31092/jpkn.v4i1S.1864

OECD menerbitkan OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 untuk menjadi pedoman dalam penerapan Transfer Pricing bagi perusahaan multinasional dan otoritas perpajakan. Penelitian ini bertujuan untuk mengidentifikasi dan menganalisis ketentuan kewajiban Transfer Pricing Documentation (TP Doc) dalam rangka meningkatkan kepatuhan pajak menurut Undang-undang Harmonisasi Peraturan (UU HPP) Nomor 7 Tahun 2021. Metode penelitian yang digunakan adalah pendekatan kualitatif dengan analisis literatur review dari hasil penelitian dan peraturan perpajakan terkait transfer pricing dan kepatuhan pajak. Hasil menunjukkan bahwa ketentuan kewajiban TP Doc dalam perpajakan atas transaksi afiliasi dengan melakukan penerapan prinsip kewajaran sesuai dengan ketentuan perpajakan. Penerapan prinsip kewajaran dan kelaziman usaha dilakukan dengan melakukan pendokumentasian dalam TP Doc. Tantangan penerapan prinsip ini adalah ketersediaan data pembanding yang handal yang dapat diakses oleh fiskus dan Wajib Pajak untuk menghindari sengketa transfer pricing. Temuan signifikan dari penelitian ini adalah banyaknya kasus sengketa transfer pricing yang diajukan oleh Wajib Pajak di Pengadilan Pajak.

Determination of Restaurant Tax Revenue Targets (Case Study in Sumedang Regency) Rd. Tatan Jaka TRESNAJAYA; Supriyadi SUPRIYADI; Nina SABNITA
International Journal of Environmental, Sustainability, and Social Science Vol. 5 No. 6 (2024): International Journal of Environmental, Sustainability, and Social Science (Nov
Publisher : PT Keberlanjutan Strategis Indonesia

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.38142/ijesss.v5i6.1249

Regional autonomy grants local governments the authority to manage administrative and financial affairs, enabling the optimization of regional revenue, particularly through Regional Original Income (PAD). A key contributor to PAD is regional taxes, including restaurant taxes. The enactment of Law Number 1 of 2022 on Financial Relations between Central and Regional Governments (HKPD) has reshaped tax collection practices, mandating alignment with the law. This study examines the case of Sumedang Regency, a district in West Java, Indonesia. This district has successfully leveraged its geographical and economic potential to exceed restaurant tax revenue targets from 2019 to 2023despite fluctuations caused by the COVID-19 pandemic. Utilizing a mixed-method approach, this research combines qualitative and quantitative analyses to explore factors influencing restaurant tax revenue, such as GRDP, tourist visits, population, number of restaurants, national inflation rate, and BI rate. The findings reveal the need for a comprehensive strategy integrating tax revenue with cross-sectoral development policies. A "Calculator" model developed in this study provides a tool for setting realistic tax revenue targets and evaluating performance. Forecasting comparisons between multiple regression and seasonal election methods indicate that the multiple regression approach, specifically the X-moderate projection, yields optimal results. This model offers evidence-based recommendations to enhance the planning and evaluation of regional tax revenue, supporting Sumedang Regency's efforts to align with the HKPD Law and optimize PAD.

Determinants of Transfer Pricing Aggressiveness of Consumer Goods Companies in Indonesia with Financial Performance as a Mediating Variable Supriyadi SUPRIYADI; Tri WIDYASTUTI; Darmansyah DARMANSYAH
International Journal of Environmental, Sustainability, and Social Science Vol. 6 No. 4 (2025): International Journal of Environmental, Sustainability, and Social Science (Jul
Publisher : PT Keberlanjutan Strategis Indonesia

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.38142/ijesss.v6i4.1526

Transfer Pricing Aggressiveness (TPA) is a strategy by multinational companies to shift profits to low-tax jurisdictions, which poses serious challenges for tax authorities in the context of Base Erosion and Profit Shifting (BEPS). Consumer goods companies in Indonesia are vulnerable to this practice due to characteristics such as leverage, company size, intangible assets, and the effective tax rate. This study aims to analyze the main determinants of TPA and explore the mediating role of financial performance in this relationship. The approach used is a mixed methods approach with an explanatory sequential design. Quantitative data were obtained from 126 financial reports of Indonesian consumer goods companies for the period 2016–2022 and analyzed using SEM-PLS. The results show that financial characteristics significantly influence TPA through financial performance as a mediator. Large and highly leveraged companies tend to manage TPA strategically, while the use of intangible assets is carried out more cautiously due to valuation and oversight risks. Financial performance serves as a signal to stakeholders and a legitimacy tool in the face of regulatory pressure. This research integrates various theoretical perspectives: Agency Theory, Resource-Based View, Institutional Theory, Tax Compliance Theory, and Legitimacy Theory. Qualitative analysis reveals regulatory challenges in Indonesia, particularly in oversight, compliance, and dispute resolution. This research provides empirical and conceptual contributions to understanding TPA strategies in developing countries and supports governance- and data-driven fiscal reforms.

Audit Plan as an Instrument to Improve the Effectiveness of Tax Audits I Gede Komang Chahya Bayu Anta KUSUMA; Irwan ARIBOWO; Supriyadi SUPRIYADI; Jai KUMAR; Niswatun Nurul KAMILAH
Journal of Governance, Taxation and Auditing Vol. 4 No. 1 (2026): Journal of Governance, Taxation and Auditing (July - September 2026)
Publisher : PT Keberlanjutan Strategis Indonesia

Show Abstract | Download Original | Original Source | Check in Google Scholar

Tax audits are an integral part of implementing the self-assessment system. The tax audit phase begins with preparatory activities, such as developing an audit plan. The audit plan encompasses several activities that must be carried out as a guideline for conducting tax audits. This study aims to determine the role of audit plans in improving the effectiveness of tax audits, particularly during the planning stage. This research used a descriptive qualitative approach, involving in-depth interviews with tax auditors and data analysis using the NVivo application. The results indicate that problem identification has been developed for each audit assignment based on available data and information. A risk-based audit plan strategy is implemented to direct the audit focus and ensure the application of methods, techniques, and procedures to obtain competent and sufficient evidence. The use of technology, such as the Derik application, facilitates audit plan development and more structured risk identification. Currently, detailed and focused audit plans help improve audit effectiveness by providing a deterrent effect and successfully obtaining competent and sufficient audit evidence that can be accounted for in the event of a tax dispute. However, the audit team's utilization of audit plans is still suboptimal, impacting audit effectiveness. This study recommends strengthening the implementation of risk-based audit plans and optimizing technology in tax audits.

Determination of Hotel Tax Revenue Targets (Case Study in Sumedang Regency) Rd. Tatan Jaka TRESNAJAYA; Supriyadi SUPRIYADI; Nina SABNITA
International Journal of Environmental, Sustainability and Social Science Vol. 5 No. 5 (2024): International Journal of Environmental, Sustainability, and Social Science (Sep
Publisher : PT Keberlanjutan Strategis Indonesia

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.38142/ijesss.v5i5.1248

Sumedang Regency, located in West Java, leverages its geographical and economic potential to enhance regional income through the management of over 40 tourist destinations and support for 475 MSMEs. Hotel tax revenue, a key component of regional income, fluctuated between 2019 and 2023, influenced by factors such as tourist numbers, room occupancy rates, and GRDP. This study aims to analyze the determinants of hotel tax revenue in Sumedang Regency within the framework of the HKPD Law, providing insights for optimizing regional revenue and supporting autonomy. Using a combination of qualitative and quantitative approaches, the study explores the impact of various factors, including GRDP, accommodation and food services, human development index, hotel availability, and population, on hotel tax revenue. Qualitative findings highlight the importance of sectoral development policies, particularly focusing on tourism and economic indicators, while quantitative analysis introduces a model called the “Calculator.” This tool aids in setting tax revenue targets and evaluating outcomes, offering the Sumedang Regency Government a data-driven approach to improving tax management and regional financial performance.

Determinants of Transfer Pricing Aggressiveness of Consumer Goods Companies in Indonesia with Financial Performance as a Mediating Variable Supriyadi SUPRIYADI; Tri WIDYASTUTI; Darmansyah DARMANSYAH
International Journal of Environmental, Sustainability, and Social Science (IJESSS) Vol. 6 No. 4 (2025): International Journal of Environmental, Sustainability, and Social Science (Jul
Publisher : PT Keberlanjutan Strategis Indonesia

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.38142/ijesss.v6i4.1526

Transfer Pricing Aggressiveness (TPA) is a strategy by multinational companies to shift profits to low-tax jurisdictions, which poses serious challenges for tax authorities in the context of Base Erosion and Profit Shifting (BEPS). Consumer goods companies in Indonesia are vulnerable to this practice due to characteristics such as leverage, company size, intangible assets, and the effective tax rate. This study aims to analyze the main determinants of TPA and explore the mediating role of financial performance in this relationship. The approach used is a mixed methods approach with an explanatory sequential design. Quantitative data were obtained from 126 financial reports of Indonesian consumer goods companies for the period 2016–2022 and analyzed using SEM-PLS. The results show that financial characteristics significantly influence TPA through financial performance as a mediator. Large and highly leveraged companies tend to manage TPA strategically, while the use of intangible assets is carried out more cautiously due to valuation and oversight risks. Financial performance serves as a signal to stakeholders and a legitimacy tool in the face of regulatory pressure. This research integrates various theoretical perspectives: Agency Theory, Resource-Based View, Institutional Theory, Tax Compliance Theory, and Legitimacy Theory. Qualitative analysis reveals regulatory challenges in Indonesia, particularly in oversight, compliance, and dispute resolution. This research provides empirical and conceptual contributions to understanding TPA strategies in developing countries and supports governance- and data-driven fiscal reforms.

Analysis of Tax Audit Authority from the Perspective of Appeal Disputes in the Tax Court Benny Setiawan; Yadhy Cahyady; Supriyadi; Faisal Ahmad Chotib
Journal of Governance, Taxation and Auditing Vol. 4 No. 3 (2026): Journal of Governance, Taxation and Auditing (January - March 2026)
Publisher : PT Keberlanjutan Strategis Indonesia

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.38142/jogta.v4i3.1756

This study analyzes the authority of tax audits conducted by the Directorate General of Taxes (DGT) from the perspective of appeal disputes in the Indonesian Tax Court. Within Indonesia’s self-assessment tax system, tax audits function as a primary instrument for ensuring taxpayer compliance and form the basis for the issuance of Tax Assessment Letters (Surat Ketetapan Pajak/SKP). However, audit results and the resulting SKP often give rise to disputes when taxpayers question both the material correctness and the procedural legitimacy of the audit process. This research employs normative legal research with a descriptive-analytical approach, examining statutory regulations, implementing rules, and relevant Tax Court decisions concerning disputes over audit authority and procedures. The findings indicate that tax audit authority is attributive and explicitly regulated under the General Provisions and Tax Procedures Law (UU KUP) and its implementing regulations. In appeal proceedings, the Tax Court assesses both formal aspects—such as compliance with audit procedures and authority—and material aspects relating to the accuracy of tax calculations. Procedural violations do not automatically invalidate a Tax Assessment Letter; instead, judges evaluate the seriousness of the violation and its impact on taxpayer rights and material truth. The study concludes that the Tax Court plays a crucial role in controlling the use of audit authority while balancing legal certainty, protection of taxpayer rights, and the state’s fiscal interests.

Supervision and Law Enforcement to Increase Taxpayer Compliance at the Pondok Aren Tax Office I Gede Komang Chahya Bayu Anta Kusuma; Supriyadi; Irwan Aribowo; Ary Widiastuti
Journal of Governance, Taxation and Auditing Vol. 4 No. 3 (2026): Journal of Governance, Taxation and Auditing (January - March 2026)
Publisher : PT Keberlanjutan Strategis Indonesia

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.38142/jogta.v4i3.1760

This study analyzes the influence of supervision and law enforcement on improving taxpayer compliance at the Pondok Aren Tax Office (KPP Pratama), focusing on post-audit Taxable Entrepreneurs (PKP). The approach used was qualitative with descriptive-analytical methods, through data collection from interviews (tax officers and taxpayers) and surveys to identify factors influencing post-audit compliance. The study results indicate that stricter supervision and effective law enforcement have the potential to improve compliance, but their implementation still faces significant obstacles such as limited resources, weak taxpayer understanding of tax obligations, and the effectiveness of sanctions that have not yet provided an adequate deterrent effect. The findings also emphasize the importance of more intensive education and outreach for new PKPs and the need to improve internal coordination (for example, between the supervisory and audit functions) to ensure more targeted post-audit follow-up. Key recommendations include strengthening technology-based supervision systems, improving tax counseling, and stricter law enforcement, including the option of freezing electronic certificates to suppress repeated violations and encourage ongoing compliance.

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