<![CDATA[Cash pooling represents a strategic cash management mechanism commonly employed in related-party transactions. This study aims to examine the underlying causes of tax disputes arising from cash pooling arrangements and to propose actionable recommendations to minimize such conflicts. Employing a qualitative research methodology, the study incorporates content analysis of tax court decisions issued between 2021 and 2023, supplemented by interviews with relevant stakeholders. The findings reveal four primary categories contributing to cash pooling-related tax disputes. These include factors related to tax auditors (competency, communication practices, and evidentiary standards), taxpayers (documentation adequacy and perceived fairness), audit methodologies (guidelines, agreement interpretations, and transaction delineation), and the lack of comprehensive domestic regulations governing cash pooling arrangements. The implications of this research are twofold. For the Directorate General of Taxes (DGT), implementing the proposed solutions could mitigate revenue losses from tax disputes. For taxpayers, enhanced clarity and regulatory alignment could lead to reduced compliance costs, fostering a more cooperative tax environment]]>
Copyrights © 2024
