<![CDATA[BEPS 2.0 has been widely analyzed as a reform of international tax rules and multinational enterprise compliance; however, its implications for state financial governance and audit accountability remain underexplored. This paper examines how Indonesia’s adoption of BEPS 2.0 instruments—UU HPP, PMK 172/2023, and PMK 136/2024—creates an implementation-effectiveness gap between the legislative mandate and enforcement capacity. Using a structured narrative review informed by a historical-institutional perspective, the study synthesizes literature on transfer pricing, BEPS 2.0, public accountability, institutional capacity, and supreme audit institutions. It develops a three-regime framework demonstrating that BEPS 2.0 does not replace arm’s length governance but instead layers GloBE, QDMTT, Amount A, and multilateral certainty requirements onto existing transfer pricing audit burdens. Three governance risks follow: a capacity-sophistication gap, transparency without utilization capacity, and regime-interaction disputes. The study further refines accountability theater as a diagnostic lens for examining gaps between formal BEPS participation and substantive accountability. For Indonesia, the central issue is whether DJP has the institutional capacity to operationalize the regulatory framework through adequate systems, human capital, information utilization, and dispute governance. Finally, the study proposes a BPK-oriented performance audit framework organized around four dimensions: legal readiness, operational readiness, information utilization, and dispute governance.]]>
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