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IMPLEMENTATION OF THE ARM'S LENGTH PRINCIPLE IN RELATED PARTY RELATIONSHIPS AT PT S INDONESIA Nuraini, Rafida; Triatmoko, Hanung; Adhi, Oscar Prasetyo; Karunia, Asaprima Putra
International Journal of Economics, Business and Accounting Research (IJEBAR) Vol 9 No 4 (2025): IJEBAR, VOL. 09 ISSUE 04, DECEMBER 2025
Publisher : LPPM ITB AAS INDONESIA (d.h STIE AAS Surakarta)

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.29040/ijebar.v9i4.18125

Abstract

This study aims to analyze the implementation of Arm’s Length Principle by PT S Indonesia in affiliated transactions with SF Co., Ltd, a parent company from Japan. The focus of the study is to assess the suitability of determining fair prices with tax regulations in Indonesia. The research method used is descriptive qualitative through interviews with tax consultants who handle the company’s transfer pricing. The analysis is carried out based on Transfer Pricing documentation and applicable tax provisions. The results of the study indicate that the use of the Transaction Net Margin Method (TNMM) is in accordance with the business characteristics of PT S Indonesia. Testing using the Profit Level Indicator (PLI) with the Berry Ratio method shows that the company’s position is within the fair range, especially in the lower interquartile. In conclusion, PT S Indonesia has implemented tax obligations in accordance with the fairness principle without any indication of tax avoidance practices, although there are obstacles in finding comparable comparisons.
Evaluation of Coretax Implementation from the Fiscus and User Perspectives: A Case Study of Primary Tax Service Office X and Tax Consultant Office Y Azzahra, Annisaa Dina; Triatmoko, Hanung; Karunia, Asaprima Putra; Wulandari, Trisninik Ratih; Endiramurti, Saktiana Rizki
AKUMULASI: Indonesian Journal of Applied Accounting and Finance Vol. 4 No. 2 (2025): December (In Press)
Publisher : Vocational School, Universitas Sebelas Maret (UNS), Indonesia

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.20961/akumulasi.v4i2.2953

Abstract

This study aims to analyze the challenges and corresponding solutions encountered during the implementation of the Core Tax Administration System or CTAS (abbreviated as Coretax), the latest innovation from the Directorate General of Taxes (DGT), from the perspectives of tax officials (fiscus) and tax consultants. This study employs a case study method with a descriptive approach. Data were obtained through observations and interviews with relevant parties at KPP Pratama X and KKP Y. This research serves as a medium for elucidating the efforts of tax authorities in addressing obstacles during CTAS implementation, as well as a platform for expressing user perspectives, particularly those of tax consultants. The results show KPP faced several challenges, including network issues, system readiness, procedural changes requiring adaptation, and reliance on centralized infrastructure. Mitigation measures included continuous monitoring, the establishment of a direct communication forum with central authorities, service adjustments, socialization initiatives, and the introduction of policies waiving administrative penalties. Both KPP and KKP stakeholders concur that, despite ongoing challenges, the system is developing and holds substantial potential to achieve its objective of modernizing tax administration to enhance user accessibility, provided consistent improvements are sustained.