Solusi Pajak Terpercaya, Kontribusi bagi Bangsa
MCAA The Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (MCAA) is a framework for the automatic exchange of information (AEoI) abetween tax authorities of different countries. The MCAA was developed by the Organization for Economic Co-operation and Development (OECD) in 2014 as part of the Common Reporting Standard (CRS) initiative. The … Read more
GAAR stands for General Anti-Avoidance Rule. It is a set of rules or provisions that give the tax authorities the power to deny tax benefits obtained by taxpayers through abusive tax arrangements. GAAR is designed to prevent taxpayers from exploiting loopholes or gaps in the tax laws to avoid paying taxes. The objective of GAAR … Read more
The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, commonly referred to as the “OECD Transfer Pricing Guidelines,”. It’s provide guidance on the application of the arm’s length principle for transfer pricing purposes. The arm’s length principle is the internationally accepted standard for determining transfer prices between related parties, such as subsidiaries of … Read more
MLI stands for “Multilateral Instrument,” which is The Multilateral Convention developed by the Organisation for Economic Co-operation and Development (OECD) to implement measures to prevent base erosion and profit shifting (BEPS) in international tax. The MLI allows countries to quickly modify their existing bilateral tax treaties to incorporate the measures developed under the BEPS project, … Read more
Article 26 of Indonesia’s Income Tax Law, also known as Witholding tax Article 26, requires Indonesian withholding agents to withhold tax at source on certain payments made to non-resident taxpayers. The tax is withheld at a rate of 20% on the gross amount of the payment, which is remitted to the Indonesian tax authority. The … Read more
An Advance Pricing Agreement (APA) is an agreement between a taxpayer and tax authority (or multiple tax authorities). this agreement establishes the transfer pricing methodology to be used for a specific set of related-party transactions for a certain period of time in the future. The purpose of an APA is to provide certainty and predictability … Read more
Transfer pricing refers to the pricing of goods, services, and intangible assets that are transferred between different entities within a multinational enterprise. It is a key issue in taxation because it can affect the allocation of profits between different jurisdictions and therefore impact the tax liabilities of each entity involved. For example, if a subsidiary … Read more
The term used for tax treaties in Indonesia is “Perjanjian Penghindaran Pajak Berganda” (P3B) In English, it is known as a double taxation avoidance agreement or a tax treaty. The P3B is an agreement between Indonesia and another country that is designed to eliminate double taxation of income and to prevent tax evasion. These agreements … Read more
In taxation, a permanent establishment (PE) is a fixed place of business through which a business carries out its activities, either wholly or partially. The concept of permanent establishment is important for determining the tax liability of a business in a foreign country. When a company operates in a foreign country through a permanent establishment, … Read more