Arifin Rosid
Faculty of Economics and Business, Universitas Indonesia, Indonesia

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Determinants of Secondary Adjustment Tax Disputes in Transfer Pricing: An Empirical Study in the Indonesian Context Hubaya Arif Auliya; Arifin Rosid
E-Jurnal Akuntansi Vol 35 No 2 (2025)
Publisher : Accounting Department, Economic and Business Faculty of Universitas Udayana in collaboration with the Association of Accounting Department of Indonesia, Bali Region

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.24843/EJA.2025.v35.i02.p06

Abstract

Tax disputes involving secondary adjustments in transfer pricing at the Indonesian Tax Court have risen, despite a decline in cases filed by the Directorate General of Taxes between 2021 and 2023. This study examines the underlying causes of these disputes through Root Cause Analysis (RCA) and Fishbone Diagrams. The analysis draws on 358 court rulings, a comprehensive literature review, and semi-structured interviews with eight key stakeholders, including judges, tax auditors, tax objection officers, and tax consultants. The findings highlight several critical factors contributing to these disputes. These include the lack of a clear definition for disguised dividends—an issue arising from the application of secondary adjustments under Indonesian regulations—varying interpretations of Ministry of Finance Regulation No. 22/2020, limited technical competence among tax auditors, and aggressive tax audit targets. These factors create legal uncertainty and increase the likelihood of disputes. To address these challenges, the study recommends clarifying relevant regulations, strengthening tax auditor training programs, and shifting the focus of tax audits from quantity to quality. Implementing these measures is expected to enhance legal certainty, reduce the frequency of disputes, and contribute to a more robust and effective tax administration system in Indonesia. Keywords: Secondary Adjustment; Transfer Pricing; Tax Disputes; Indonesian Tax Court; Root Cause Analysis
Tax Management Analysis of VAT and Its Implications for the Liquidity of Construction Companies Cempaka Effendi Gunawan; Arifin Rosid
E-Jurnal Akuntansi Vol. 35 No. 7 (2025)
Publisher : Fakultas Ekonomi dan Bisnis Universitas Udayana

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.24843/EJA.2025.v35.i07.p13

Abstract

The construction sector ranks as the fifth-largest contributor to Value Added Tax )VAT) revenue in Indoneisa. In 2023, total tax revenue realization rached 102.80%, with VAT and Sales Tax on Luxury Good (STLG) contributing 40.9%, highlighting the sector’s strategic role in achieving tax targets. This study aims to evaluate the effectiveness of VAT-related tax management and cash flow management in construction company that has been designated as a taxable entrepreneur (PKP). A case study approach was employed using primary data from interviews with the company’s finance and tax divisions as well as external tax consultants, supported by internal documents and financial statements as secondary data. The findings reveasl that both tax and xash management are ineffective due to the absence of formal tax planning, specifics SOPs, and cash flow challenges caused by delayed client payments. The study recommends establishing a separate tax function, implementing tax-specific SOPs and internal audits, and intergrating financial tax and systems.
Evaluation of the Deposit System for Tax Payment within the Coretax System Andri Adi Nugroho; Arifin Rosid
E-Jurnal Akuntansi Vol. 35 No. 12 (2025)
Publisher : Fakultas Ekonomi dan Bisnis Universitas Udayana

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.24843/EJA.2025.v35.i12.p08

Abstract

This study evaluates the implementation of the Coretax deposit system using the OECD (2021) framework (relevance, effectiveness, impact, and sustainability) for research question indicators. A descriptive qualitative evaluation case study method was used for data collection and analysis. The study involved taxpayers and tax officers at KPP Madya Dua Jakarta Utara. The results showed that the relevance criterion was met, as the system effectively addressed taxpayers' administrative needs. The sustainability criterion was met because taxpayers expressed their commitment to continue using this system, citing its long-term benefits. The effectiveness criterion has not been fully met due to technical obstacles, including failures to update ledger balances in real time and an automatic FIFO-based deduction mechanism that creates the potential for interest penalties. The impact criterion has not been met because the deposit system does not change behavior; it is only a formality to avoid late penalties when technical obstacles arise
Determinants of Secondary Adjustment Tax Disputes in Transfer Pricing: An Empirical Study in the Indonesian Context Hubaya Arif Auliya; Arifin Rosid
E-Jurnal Akuntansi Vol. 35 No. 2 (2025)
Publisher : Fakultas Ekonomi dan Bisnis Universitas Udayana

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

Abstract

Tax disputes involving secondary adjustments in transfer pricing at the Indonesian Tax Court have risen, despite a decline in cases filed by the Directorate General of Taxes between 2021 and 2023. This study examines the underlying causes of these disputes through Root Cause Analysis (RCA) and Fishbone Diagrams. The analysis draws on 358 court rulings, a comprehensive literature review, and semistructured interviews with eight key stakeholders, including judges, tax auditors, tax objection officers, and tax consultants. The findings highlight several critical factors contributing to these disputes. These include the lack of a clear definition for disguised dividends—an issue arising from the application of secondary adjustments under Indonesian regulations—varying interpretations of Ministry of Finance Regulation No. 22/2020, limited technical competence among tax auditors, and aggressive tax audit targets. These factors create legal uncertainty and increase the likelihood of disputes. To address these challenges, the study recommends clarifying relevant regulations, strengthening tax auditor training programs, and shifting the focus of tax audits from quantity to quality. Implementing these measures is expected to enhance legal certainty, reduce the frequency of disputes, and contribute to a more robust and effective tax administration system in Indonesia.