Indonesian Tax Justice Review
Indonesian Tax Justice Review (e-ISSN: 3164-7553) is published by COLLEGIUM JUSTICIA INDONESIA, issued four times a year in February, May, August, and November, and was first published in 2024. It is a double anonymous peer-reviewed academic journal focusing on the relationship between tax law, public policy, and social justice in Indonesia. The journal publishes scholarly works examining taxation, tax policy, tax administration, taxpayer rights, tax fairness, transparency, accountability, public finance, and the role of taxation in reducing inequality and supporting social welfare. It also welcomes studies on tax avoidance and evasion, international tax justice, digital economy taxation, tax reform, and legal and policy developments in the taxation sector. The journal encourages interdisciplinary research from law, economics, political science, public policy, and related fields. It publishes original research articles, review articles, case studies, policy analyses, and other scholarly works relevant to its scope. The journal applies an Open Access Policy, providing free and immediate access to published articles. Copyright is retained by the authors, and articles are published under the Creative Commons Attribution 4.0 International (CC BY 4.0) license.
Articles
55 Documents
<![CDATA[Tax Justice in the Mining Sector: Indonesia’s Royalty and Income Tax Regime Revisited ]]>
<![CDATA[Retno Wening Kusumadewi]]>;
<![CDATA[Shakti Kirana Paramita]]>
<![CDATA[ Indonesian Tax Justice Review Vol. 2 No. 1 (2025): February, 2025 ]]>
Publisher : <![CDATA[COLLEGIUM JUSTICIA INDONESIA ]]>
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DOI: 10.65815/mcbqwr27
<![CDATA[The extractive industry constitutes a critical source of public revenue for resource-rich developing countries, yet it remains highly susceptible to tax base erosion and unequal rent distribution. This paper examines Indonesia’s mining sector taxation framework, focusing on the interaction between royalty regimes, corporate income taxation, and contractual arrangements with multinational mining corporations. Using doctrinal legal analysis combined with policy evaluation, the study assesses whether Indonesia’s fiscal design ensures an equitable allocation of natural resource rents between the state and private investors. The analysis reveals that stability clauses, preferential tax treatments, and limited renegotiation mechanisms significantly reduce the effective tax burden borne by mining companies. These features weaken vertical equity and constrain the state’s capacity to capture extraordinary profits during commodity booms. The paper argues that Indonesia’s experience reflects broader structural challenges faced by developing countries in taxing extractive industries within globalized capital markets. The global contribution of this study lies in providing sector-specific evidence on how legal and contractual design shapes tax justice outcomes in resource-dependent economies. By situating Indonesia’s mining tax regime within international debates on extractive sector governance, the paper offers policy-relevant insights for reforming royalty systems, strengthening progressive rent capture, and enhancing transparency. These findings contribute to global tax justice scholarship by emphasizing that equitable extractive taxation requires both robust legal frameworks and institutional capacity to renegotiate power asymmetries between states and multinational enterprises.]]>
<![CDATA[Palm Oil Taxation and Environmental Justice: Fiscal Policy Challenges in Indonesia ]]>
<![CDATA[Kenanga Larasati Cahyani]]>;
<![CDATA[Ratih Maheswari]]>
<![CDATA[ Indonesian Tax Justice Review Vol. 2 No. 1 (2025): February, 2025 ]]>
Publisher : <![CDATA[COLLEGIUM JUSTICIA INDONESIA ]]>
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DOI: 10.65815/frkbka56
<![CDATA[Indonesia is the world’s largest producer of palm oil, generating significant export revenues while simultaneously contributing to environmental degradation and social inequality. This paper examines Indonesia’s palm oil taxation policies through the combined lenses of tax justice and environmental justice. Using legal and policy analysis, the study evaluates export levies, corporate income taxation, and sector-specific fiscal incentives applied to palm oil producers. The findings indicate that existing tax instruments inadequately internalize environmental externalities and disproportionately favor large-scale corporate producers. Smallholders often face compliance burdens without corresponding fiscal support or redistributive benefits. The paper argues that the current fiscal framework fails to align revenue mobilization with sustainability and equity objectives. The global contribution of this study lies in linking commodity taxation with environmental justice concerns in developing countries integrated into global supply chains. Indonesia’s experience illustrates how sector-specific tax policy can reinforce global environmental inequality by allowing environmental costs to be externalized to local communities. The study contributes to international tax justice literature by advocating for integrated fiscal-environmental approaches that combine taxation, redistribution, and environmental accountability. These findings are relevant for other commodity-dependent economies seeking to design tax policies that support both development and sustainability goals.]]>
<![CDATA[Transfer Pricing Risks in the Mining Sector: Evidence from Indonesian Tax Disputes ]]>
<![CDATA[Padma Kirana Jayanti]]>;
<![CDATA[Abigail Helena Saraswati]]>
<![CDATA[ Indonesian Tax Justice Review Vol. 2 No. 1 (2025): February, 2025 ]]>
Publisher : <![CDATA[COLLEGIUM JUSTICIA INDONESIA ]]>
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DOI: 10.65815/bczkvx36
<![CDATA[Transfer pricing practices in the mining sector present significant risks to revenue mobilization in developing countries due to concentrated markets and limited price comparables. This paper analyzes Indonesian tax disputes involving multinational mining companies to assess the effectiveness of transfer pricing enforcement. Using doctrinal case law analysis, the study examines disputes related to related-party sales, cost allocation, and pricing of mineral exports. The findings reveal persistent information asymmetries between tax authorities and multinational enterprises, compounded by limited access to reliable comparables and technical expertise. These constraints weaken the enforcement of the arm’s length principle and reduce effective taxation of extractive profits. The paper argues that Indonesia’s experience highlights structural limitations of traditional transfer pricing methods in extractive industries. The global contribution of this study lies in providing sector-specific empirical evidence supporting calls for alternative profit allocation approaches, such as formulary or rent-based taxation. By situating Indonesian disputes within global tax justice debates, the study contributes to rethinking international tax rules for sectors characterized by high capital intensity and market concentration.]]>
<![CDATA[Digital Platforms and VAT Collection: Justice Implications of Indonesia’s Marketplace Regime ]]>
<![CDATA[Safira Zahra Amara]]>
<![CDATA[ Indonesian Tax Justice Review Vol. 2 No. 1 (2025): February, 2025 ]]>
Publisher : <![CDATA[COLLEGIUM JUSTICIA INDONESIA ]]>
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DOI: 10.65815/ackm3b26
<![CDATA[The expansion of digital platforms has fundamentally altered consumption patterns and challenged conventional VAT collection mechanisms. This paper examines Indonesia’s policy requiring digital marketplaces to collect and remit VAT on behalf of sellers. Using doctrinal and policy analysis, the study evaluates the effectiveness and equity implications of this regime for platform operators, small sellers, and consumers. The findings indicate that marketplace-based VAT collection significantly improves compliance and reduces revenue leakage in cross-border digital transactions. However, the policy also shifts administrative burdens onto platforms and small merchants, potentially exacerbating inequalities within the digital economy. The paper argues that VAT reforms targeting digital platforms must balance efficiency gains with taxpayer equity. The global contribution of this study lies in offering a concrete policy case from a developing economy addressing digital VAT challenges. Indonesia’s experience provides transferable lessons for countries seeking to tax digital consumption while preserving inclusivity. The study contributes to global tax justice literature by demonstrating that digital VAT design should incorporate proportional compliance obligations and targeted support mechanisms for small economic actors.]]>
<![CDATA[Taxation of Digital Advertising Services: Indonesia’s Policy Response and Global Relevance ]]>
<![CDATA[Wulan Purnamasari]]>
<![CDATA[ Indonesian Tax Justice Review Vol. 2 No. 1 (2025): February, 2025 ]]>
Publisher : <![CDATA[COLLEGIUM JUSTICIA INDONESIA ]]>
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DOI: 10.65815/3x965f38
<![CDATA[Digital advertising services generate substantial economic value in market jurisdictions without requiring physical presence. This paper analyzes Indonesia’s taxation of digital advertising services and its implications for tax justice. Using normative legal analysis, the study evaluates the application of VAT and withholding taxes to foreign digital advertising providers. The findings suggest that while Indonesia’s measures enhance short-term revenue collection, enforcement challenges persist due to cross-border complexity and limited international coordination. The paper argues that unilateral digital taxation measures offer partial solutions but cannot fully address structural inequities in taxing digital value creation. The global contribution of this study lies in providing a developing country perspective on taxing digital advertising revenues. Indonesia’s experience informs international debates on reallocating taxing rights in the digital economy and highlights the limitations of interim solutions. The study contributes to global tax justice scholarship by emphasizing the need for coordinated international reforms that prioritize market jurisdictions.]]>
<![CDATA[Supreme Court Jurisprudence on Tax Avoidance: A Critical Review of Indonesian Decisions ]]>
<![CDATA[Raras Pitaloka Handayani]]>
<![CDATA[ Indonesian Tax Justice Review Vol. 2 No. 2 (2025): May, 2025 ]]>
Publisher : <![CDATA[COLLEGIUM JUSTICIA INDONESIA ]]>
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DOI: 10.65815/15wa0c64
<![CDATA[Judicial interpretation plays a decisive role in shaping tax justice outcomes. This paper examines selected Indonesian Supreme Court decisions addressing tax avoidance and aggressive tax planning. Using doctrinal jurisprudential analysis, the study evaluates judicial reasoning, consistency, and the application of economic substance principles. The findings reveal divergent interpretations and a tendency toward formalistic reasoning, which may limit the effectiveness of anti-avoidance rules. The paper argues that inconsistent jurisprudence undermines legal certainty and weakens deterrence against aggressive tax planning. The global contribution of this study lies in demonstrating how apex court jurisprudence influences the enforcement of tax justice in developing countries. Indonesia’s Supreme Court decisions provide comparative insights for jurisdictions seeking to strengthen judicial responses to tax avoidance. The study contributes to global debates on the role of courts in advancing equitable taxation by highlighting the importance of coherent doctrine and judicial capacity.]]>
<![CDATA[Judicial Review of Transfer Pricing Cases at the Supreme Court Level in Indonesia ]]>
<![CDATA[Elijah Samuel Wiratama]]>
<![CDATA[ Indonesian Tax Justice Review Vol. 2 No. 2 (2025): May, 2025 ]]>
Publisher : <![CDATA[COLLEGIUM JUSTICIA INDONESIA ]]>
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DOI: 10.65815/08kt7267
<![CDATA[Supreme Court review of transfer pricing disputes significantly affects the balance of power between tax authorities and multinational enterprises. This paper analyzes Indonesian Supreme Court rulings on transfer pricing cases to assess their implications for tax justice. Using case law analysis, the study examines standards of proof, evidentiary requirements, and interpretations of the arm’s length principle. The findings suggest that strict formalism often disadvantages tax authorities, particularly in cases involving complex cross-border transactions. The paper argues that judicial reluctance to engage with economic substance undermines effective enforcement. The global contribution of this study lies in highlighting how apex court jurisprudence shapes the practical enforceability of international tax rules. Indonesia’s experience offers lessons for strengthening judicial approaches to transfer pricing disputes in developing countries.]]>
<![CDATA[Windfall Profit Taxation in the Mining Sector: Lessons from Indonesia’s Policy Debate ]]>
<![CDATA[Ihsan Rafif Alfaruq]]>;
<![CDATA[Sasmita Citra Pertiwi]]>
<![CDATA[ Indonesian Tax Justice Review Vol. 2 No. 2 (2025): May, 2025 ]]>
Publisher : <![CDATA[COLLEGIUM JUSTICIA INDONESIA ]]>
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DOI: 10.65815/fcejhk03
<![CDATA[Commodity price volatility has renewed interest in windfall profit taxation as a tool for equitable revenue mobilization. This paper examines Indonesia’s policy debates surrounding windfall taxes in the mining sector. Using policy and legal analysis, the study evaluates the equity rationale, revenue potential, and legal feasibility of windfall taxation. The findings suggest that windfall taxes can enhance distributive justice by capturing extraordinary profits during commodity booms, provided that design and implementation are transparent. The global contribution of this study lies in offering a developing country perspective on windfall taxation in extractive industries. Indonesia’s experience contributes to international debates on resource rent sharing and fiscal justice during periods of price volatility.]]>
<![CDATA[Taxation of Cross-Border Digital Services after Supreme Court Rulings in Indonesia ]]>
<![CDATA[Rayyan Harits Anshari]]>
<![CDATA[ Indonesian Tax Justice Review Vol. 2 No. 2 (2025): May, 2025 ]]>
Publisher : <![CDATA[COLLEGIUM JUSTICIA INDONESIA ]]>
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DOI: 10.65815/9fs40b66
<![CDATA[Recent Indonesian Supreme Court rulings have addressed the taxation of cross-border digital services. This paper analyzes these decisions to assess their implications for tax justice and digital economy governance. Using jurisprudential analysis, the study examines interpretations of permanent establishment and source rules. The findings indicate evolving judicial recognition of digital economic presence. The global contribution of this study lies in offering early judicial insights from a developing country confronting digital taxation challenges. Indonesia’s experience informs international debates on adapting tax concepts to digital business models and contributes to global tax justice scholarship.]]>
<![CDATA[Sectoral Tax Justice and Global Value Chains: Evidence from Indonesia’s Resource and Digital Sectors ]]>
<![CDATA[Ethan Josiah Santoso]]>;
<![CDATA[Ni Luh Putu Candrawati]]>
<![CDATA[ Indonesian Tax Justice Review Vol. 2 No. 2 (2025): May, 2025 ]]>
Publisher : <![CDATA[COLLEGIUM JUSTICIA INDONESIA ]]>
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DOI: 10.65815/e6kjg431
<![CDATA[Global value chains shape how profits are distributed across jurisdictions. This paper compares tax justice outcomes in Indonesia’s mining, palm oil, and digital sectors. Using comparative sectoral analysis, the study examines how value chain positioning affects taxing rights. The findings reveal systematic disadvantages for source countries. The global contribution of this study lies in integrating sectoral analysis into tax justice discourse. Indonesia’s experience offers insights for rethinking taxation in globalized production systems.]]>
