Article Per Year (5 Year)
p-Index From 2021 - 2026
0.408
P-Index
This Author published in this journals
All Journal Al-Manhaj: Jurnal Hukum dan Pranata Sosial Islam Prosiding Seminar Hukum Aktual Fakultas Hukum Universitas Islam Indonesia
Nathan Thomas
Unknown Affiliation
Religion Humanities Economics, Econometrics & Finance Law, Crime, Criminology & Criminal Justice

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

Found 2 Documents
Search

 1 
Advance Pricing Agreement for Preventing Transfer Pricing Disputes in International Trade Law Nathan Thomas; Hafid Zakariya; Diajeng Lita Pratiwi
Prosiding Seminar Hukum Aktual Fakultas Hukum Universitas Islam Indonesia Vol. 4 No. 3 MEI 2026
Publisher : Fakultas Hukum Universitas Islam Indonesia

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

Abstract

Companies often engage in purchase and sale transactions with related parties. Some companies utilize such transactions as instruments in transfer pricing practices. Advance Pricing Agreement is a written agreement mechanism used to determine the arm’s length price for transactions between related parties. This study aims to analyze the implementation mechanism of the Advance Pricing Agreement in preventing transfer pricing disputes and to examine the challenges of its implementation from the perspective of international trade law. The author employs a normative juridical research method, using a statutory approach and a case study approach involving transfer pricing disputes such as PT Covestro Polymers Indonesia and Court Decision No. PUT 003777.15/2023/PP/M.XVIIIA (2024) in the case of PT VVF Indonesia vs the Directorate General of Taxes (DGT), which discusses the application of the Advance Pricing Agreement in resolving tax disputes. The findings indicate that the implementation of the Advance Pricing Agreement serves as a legal instrument capable of creating legal certainty, transparency, and efficiency in resolving potential transfer pricing disputes. Minister of Finance Regulation (PMK) No. 172/2023 strengthens the legal foundation for Advance Pricing Agreement implementation in Indonesia. However, several challenges remain in its practical application. Overall, the study concludes that the Advance Pricing Agreement functions as a legal solution to prevent transfer pricing disputes and reinforces the arm’s length principle within the framework of international trade law.
Criminal Tax Law Strategy Regarding Fictitious Tax Invoices for Business Sustainability Nathan Thomas; Nourma Dewi; Firstnandiar Glica Aini Suniaprily
AL-MANHAJ: Jurnal Hukum dan Pranata Sosial Islam Vol. 8 No. 1 (2026)
Publisher : Fakultas Syariah INSURI Ponorogo

Show Abstract | Download Original | Original Source | Check in Google Scholar | DOI: 10.37680/almanhaj.v8i1.9599

Abstract

This study aims to examine criminal tax law provisions in Indonesia relating to the issuance of fictitious tax invoices, as well as to analyze criminal law enforcement strategies applicable to cases of fictitious tax invoices at PT PP. A fictitious tax invoice is an invoice issued without any actual transaction to reduce tax liabilities. This research is a normative study using a case and statistical approaches. The results show that the Indonesian taxation system, such as VAT, adopts a self-assessment system that is exploited for fraud, including fictitious tax invoices, as happened to PT PP. As a result, the DGT issued a warning, deactivated access to tax invoice creation, and is potentially subject to administrative sanctions in the form of a 100% increase in unpaid VAT in accordance with Article 15 paragraph (2) of the KUP Law. In addition to administrative sanctions, the issuance and/or use of fictitious tax invoices based on Article 39A of the KUP Law is punishable by a maximum imprisonment of 6 years and a maximum fine of 6 times the amount of tax in the tax invoice.
Co-Authors Diajeng Lita Pratiwi Firstnandiar Glica Aini Suniaprily Hafid Zakariya Nourma Dewi