ANALISIS PENERAPAN CONTROLLED FOREIGN COMPANY RULES DALAM MENGATASI BASE EROSION AND PROFIT SHIFTING DI INDONESIA

INFO ARTHA

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Field Value
 
Title
ANALISIS PENERAPAN CONTROLLED FOREIGN COMPANY RULES DALAM MENGATASI BASE EROSION AND PROFIT SHIFTING DI INDONESIA
 
Creator Mightyn, Alfa
Andriani, Arifah Fibri
 
Subject
Controlled Foreign Company (CFC) Rules; Indonesia; Base Erosion and Profit Shifting (BEPS)
 
Description
One cause for the inability to achieve the expected tax revenue target for some last years was the practice of tax avoidance. One form of tax avoidance is the utilization of Controlled Foreign Company (CFC) to defer the recognition of income from overseas over WPDN capital to be taxed in the country. This practice is also faced by many other countries in the world. The issue of the Base Erosion and Profit Shifting (BEPS) has been of concern to developed and developing countries. G20 countries cooperate with OECD to form a BEPS Project to formulate measures to address these BEPS. Indonesia as one of the Associate Members of the Project BEPS has a position that is parallel to the other OECD countries and participates in implementing the BEPS results. BEPS Project has resulted in BEPS Action Plans which one of them is Action 3: Strengthening CFC Rules. Action 3 will provide recommendations to the domestic law related to the design of CFC Rules. Until now, related to Action 3, BEPS Project has issued a Public Discussion Draft Action 3: Strengthening CFC Rules. This draft is divided into seven "building blocks" required for CFC Rules to be effective. The aim of this study is to analyze the effectiveness of CFC Rules in Indonesia, whether it is sufficient to prevent BEPS. After that, we can determine what steps should be taken by Indonesian tax authorities to strengthen the CFC Rules in Indonesia based on seven dimensions of building blocks. The conclusions of this study are (1) CFC Rules in Indonesia as a whole have not been able to overcome BEPS; and (2) When compared with the recommendations of the Discussion Draft Action Plan 3, CFC Rules Indonesia needs to be improved. However, the necessary improvements should be adjusted to match the needs and characteristics of Indonesia. 
 
Publisher Polytechnic of State Finance STAN
 
Contributor

 
Date 2017-05-23
 
Type info:eu-repo/semantics/article
info:eu-repo/semantics/publishedVersion
Peer-reviewed Article
 
Format application/pdf
 
Identifier http://jurnal.pknstan.ac.id/index.php/JIA/article/view/53
10.31092/jia.v3i0.53
 
Source INFO ARTHA; Vol 3 (2016): Edisi Maret; 1-14
JURNAL INFO ARTHA; Vol 3 (2016): Edisi Maret; 1-14
2581-0839
0852-6737
10.31092/jia.v3i0
 
Language ind
 
Relation http://jurnal.pknstan.ac.id/index.php/JIA/article/view/53/41
 
Rights Copyright (c) 2017 INFO ARTHA
 

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