Article Per Year (5 Year)
p-Index From 2021 - 2026
0.23
P-Index
This Author published in this journals
All Journal Jurnal Pajak Indonesia (Indonesian Tax Review)
Vita Apriliasari
Unknown Affiliation
Economics, Econometrics & Finance

Published : 2 Documents Claim Missing Document
Claim Missing Document
Check
Articles

Found 2 Documents
Search

 1 
INTERPRETATION ISSUE OF THE PRINCIPAL PURPOSE TEST Vita Apriliasari
JURNAL PAJAK INDONESIA Vol 3 No 2 (2019): Perpajakan dalam Keuangan Negara II
Publisher : Politeknik Keuangan Negara STAN

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.31092/jpi.v3i2.734

Abstract

The existence of tax treaties has raised a base erosion and profit shifting (BEPS) concern through the circumvention of the provisions of those treaties. Consequently, following the release of the BEPS Action 6 Final Report by the Organisation for Economic Co-operation and Development, the Principal Purpose Test (PPT) has been introduced as a general anti abuse rule (GAAR) for tax treaties. As a BEPS action minimum standard, the PPT clauses are considered sufficient to prevent tax treaty abuses. However, since there has been no sufficiently clear guidance to the PPT implementation, several interpretation issues seem to arise. This situation is likely to put uncertainties for both tax administrations and taxpayers. This article aims to provide a literature review of the PPT clauses interpretation so as to help them to further address such issues. The discussion focuses on 4 (four) main elements of the PPT, (1) the interpretation of the phrase “one of the principal purposes”; (2) the reasonableness element; (3) the object and purpose of the relevant treaty provision; and (4) the burden of proof of the PPT.
OECD/G20 PILLAR TWO: IS IT A COMPATIBLE AND FEASIBLE SOLUTION? Vita Apriliasari
JURNAL PAJAK INDONESIA Vol 5 No 2 (2021): Kebijakan Perpajakan era Omnibus Law dan Implementasinya - II
Publisher : Politeknik Keuangan Negara STAN

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.31092/jpi.v5i2.1400

Abstract

This study aims to contribute to the continuing discussion about the compatibility and feasibility of the OECD/G20 Pillar Two measures as a solution to address the remaining base erosion and profit-shifting (BEPS) issues. One triggering such a discussion is the significance of Pillar Two for developing countries. In so doing, a literature review is conducted to gain relevant considerations to the Pillar Two implementation. The analysis lead to the comprehension of the issues surrounding Pillar Two, i.e. justification, complicated design, fairness issues, and effectiveness.
Co-Authors