Aspek hukum transfer pricing

Lawa, Simson Alberthinus (2003) Aspek hukum transfer pricing. Masters thesis, Universitas Pelita Harapan.

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Abstract

For the last decades, transfer pricing has been one of the most important issues for both tax authorities and multinational corporations. On the one hand, tax authorities, despite their countermeasures, have not been able to cope with the international tax avoidance 'or evasion using transfer pricing by multinational corporations owing to the deficiency of tax systems and the inability of tax administrators and this has resulted in a huge revenue loss to the coffers of their countries. On the other hand, while multinational corporations have been using transfer pricing as vehicles to maximize their overall after-tax profits as a group, they have been suffering intolerable administrative burdens and double taxation caused by enforcement of countermeasures by tax authorities so unfair trade impact can be happen of course. The basic principle for transfer pricing taxation legislation is the "arm's length principle", that transactions between parties that are not dealing at arm's length should be carried out for tax purposes under terms and at a price that one could reasonably have expected in similar circumstance had the parties been dealing at arm's length. At present, the situation already shows some improvements due to efforts for the harmonization of guidelines among tax authorities, and due to multinational corporations' application of transfer pricing policy in a more self-restricted manner, and more appropriate advice from tax practitioners. However, there is still room for possible improvements. To a multinational group of companies as a whole, in principle, the transfer price does not make much difference as long as the goods or services do not leave the group. Indeed, a real transaction profit or loss to the group accurs only after the goods or services are sold to parties outside the group.

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