THE ANALYSIS OF TAX DISPUTE RESOLUTION OF TRANSFER PRICING CALCULATION

Determining transfer prices is one of the legal methods in the field of taxation that can be used to obtain the most optimal profits for multinational companies by trying to get the lowest tax rates. The Indonesian government has regulated methods that can be used to calculate transfer prices between related entities. However, the transfer price calculation is still often a dispute between the Directorate General of Taxes (DGT) and Taxpayers (TP), the resolution of which takes a very long time and is mostly won by the Taxpayer. This is a burden for taxpayers and also for the government and can affect the business and investment climate. Based on this, the implementation of tax dispute resolution outside of court (non-litigation) or Alternative Dispute Resolution (ADR) can be considered, providing consultation services when taxpayers prepare transfer price documents, as soon as possible the DGT reviews the TP Doc that has been prepared and submitted by the taxpayer and regulate the criteria and procedures for selecting data / comparison companies in more detail.