Taxes are one of the main sources of revenue for the country, and along with the globalization of the economy, the practice of transactions between affiliated companies (transfer pricing) has become an increasingly relevant issue. Transfer pricing is concerned with determining the price of goods, services, or assets exchanged between companies that have an affiliate relationship. In Indonesia, the Directorate General of Taxes (DGT) pays great attention to the practice of transfer pricing, considering the potential for tax evasion through inappropriate pricing in transactions between companies. This study aims to examine the perspective of tax law related to transfer pricing transactions in Indonesia, focusing on applicable tax regulations, provisions related to transfer pricing, and law enforcement efforts carried out by the DGT. The study also discusses various challenges and problems that arise in the implementation of transfer pricing regulations in Indonesia, such as difficulties in determining fair prices and the possibility of abuse by multinational companies. It is hoped that the results of this study can provide an understanding of the effectiveness of existing tax policies in dealing with transfer pricing problems and provide recommendations to improve the level of tax compliance in Indonesia.
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