| 000 | 02448nab a2200289 c 4500 | ||
|---|---|---|---|
| 999 |
_c142787 _d142787 |
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| 003 | ES-MaIEF | ||
| 005 | 20200923191323.0 | ||
| 007 | ta | ||
| 008 | 200923t2020 ne ||||oo|||| 00| 0|eng d | ||
| 040 |
_aES-MaIEF _bspa _cES-MaIEF |
||
| 041 | _aeng | ||
| 100 | 1 |
_967382 _aTambunan, Maria R.U.D. |
|
| 245 | 0 |
_aTransfer Pricing cases on intangibles performed by manufacturing industry based on tax court decisions 2015-2019 in Indonesia _c Maria R.U.D. Tambunan, Haula Rosdiana and Edi Slamet Irianto _hElectrónico |
|
| 260 | _c2020 | ||
| 500 | _aDisponible únicamente en formato electrónico. | ||
| 500 | _aResumen. | ||
| 520 | _aThis article aims to discuss transfer pricing disputes regarding the payments made on intangible assets by the Indonesian subsidiaries of MNEs operating as contract manufacturers. The underlying premise for assessing the manufacturing industry relates to its leading role in the Indonesian economy. In reality, most multinational contract manufacturers located in Indonesia perform only a limited function, assume only limited risk and are highly dependent on their principal with regard to business decisions. Payments on intangibles were the most prolific type of cases brought to the tax court in Indonesia during the fiscal years 2015-2019. Disputes typically arose from the technical aspect in a tax assessment concerning the payment made on intangibles to the principal, along with the interpretation of tax regulation regarding the existence of the transaction and the existence of proof of the transaction. The Indonesian tax authority has created a procedure for auditing payment on intangibles; however, the current tax rule is considered inadequate. To improve the current tax audit, an assessment of the existence of value creation, which is the principal motor of business competitiveness, should be the main objective of the audit. A value creation audit might refer to the significant business function performed in Indonesia as part of an MNE's global value chain. | ||
| 650 | 4 |
_948095 _aPRECIOS DE TRANSFERENCIA |
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| 650 | 4 |
_943551 _aEMPRESAS MANUFACTURERAS |
|
| 650 | 4 |
_aACTIVOS INVISIBLES _95175 |
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| 650 | 4 |
_aINDONESIA _947477 |
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| 650 | 4 |
_aJURISPRUDENCIA _947570 |
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| 700 | 1 |
_968208 _aRosdiana, Haula |
|
| 700 | 1 |
_968209 _aIrianto, Edi Slamet |
|
| 773 | 0 |
_9163276 _oITPJ/2020/5 _tInternational Transfer Pricing Journal _w(IEF)65014 _x 1385-3074 _gv. 27, n. 5, 2020, 8 p. |
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| 942 | _cRE | ||