Penerapan Prinsip Kewajaran Transaksi dalam Aktivitas Transfer Pricing
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Institusion
Politeknik Negeri Bali
Author
Dewi, Sinta Kusuma
Subject
Perpajakan
Datestamp
2024-09-01 06:24:43
Abstract :
Global economic development cannot be separated from the role of multinational companies. Companies that have affiliates and subsidiaries in various countries are categorized as multinational companies and the transactions carried out can be classified as transactions with special relationships. The Organization for Economic Co-operation and Development (OECD) published the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 as guidelines for implementing Transfer Pricing for multinational companies and tax authorities. Type 3 Agency Theory exists to explain the differences in interests that occur between tax authorities and taxpayers due to improper transactions of multinational companies with their affiliates. So it is necessary to apply transaction fairness analysis to handle this phenomenon. This research uses qualitative methods with discourse analysis (Content Analysis) from webinar videos or research participant learning related to Related Party Transactions and the Arm's Length Principle (ALP). Research partisipants are professionals in the field of transfer pricing from various countries. The research results illustrate that ALP is an international standard for determining reasonable transfer prices that occur between companies that have a special relationship. So ALP is an absolute regulation for dealing with special relationship transactions. However, it is still too early to conclude whether the implementation of the OECD TPG 2022 in Indonesia is successful enough to obtain significant tax revenue. The significant research findings explaining Agency Theory and Arm's Length Principle Theory can be concluded that these are two important concepts related to affiliate transactions between multinational companies and their subsidiaries.
Global economic development cannot be separated from the role of multinational companies. Companies that have affiliates and subsidiaries in various countries are categorized as multinational companies and the transactions carried out can be classified as transactions with special relationships. The Organization for Economic Co-operation and Development (OECD) published the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 as guidelines for implementing Transfer Pricing for multinational companies and tax authorities. Type 3 Agency Theory exists to explain the differences in interests that occur between tax authorities and taxpayers due to improper transactions of multinational companies with their affiliates. So it is necessary to apply transaction fairness analysis to handle this phenomenon. This research uses qualitative methods with discourse analysis (Content Analysis) from webinar videos or research participant learning related to Related Party Transactions and the Arm's Length Principle (ALP). Research partisipants are professionals in the field of transfer pricing from various countries. The research results illustrate that ALP is an international standard for determining reasonable transfer prices that occur between companies that have a special relationship. So ALP is an absolute regulation for dealing with special relationship transactions. However, it is still too early to conclude whether the implementation of the OECD TPG 2022 in Indonesia is successful enough to obtain significant tax revenue. The significant research findings explaining Agency Theory and Arm's Length Principle Theory can be concluded that these are two important concepts related to affiliate transactions between multinational companies and their subsidiaries.
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