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Taxes and currency factors have a major influence on investment decisions, forms of organization, funding sources, when / where the recognition of revenue / expense, and transfer pricing.Most companies are burdened with the problem of the tax code (in addition to COGS, Labor, and Raw Materials). Because the tax code of each country differ, the company needs to have a system of multinational tax planning and computer-based simulation system as an essential tool of management.

The company must understand the main differences of national taxation system, a national effort to address the issue of double taxation and arbitrage opportunities between national jurisdictions for multinational companies.

Transfer pricing to minimize the role of national corporate tax, but also must consider the context of strategic planning and control.

• Diversity of the National Tax System

Various kinds of taxes:

– Direct taxes, such as CHD Charges and VAT

– Indirect taxes, such as CHD Border

– Corporate Tax, such as Transfer Tax

Tax Burden

Tax Administration System:

– Classical System

Corporate income tax imposed on taxable income at the corporate level and shareholder level.

– Integrated Systems

Corporate tax and shareholder integrated in such a way as to reduce or eliminate double taxation

on corporate earnings.

Tax incentives LN:

– Tax holiday

Incentives may include tax-free cash grants are used for the cost of fixed assets and new

industrial processes or remission of taxes to pay for some period of time

– Tax havens

Negar that have special tax privileges may also be considered a tax haven in a time-limited

Harmful Tax Competition

International Harmonization

• Against Pamajakan LN and Sources of Income Taxation

– Foreign Tax Credit

– Restrictions on Tax Credit

– Tax Treaty

– Consider Foreign Currency

• Definition of Tax Planning

– Consideration of the Organization

– Foreign-controlled companies and Profit Subdivision F

– Parent Company in LN

– Corporate Sales LN

– Funding Decisions

– Merger Tax Credit

– Cost Accounting Aokasi

– Location and Transfer Pricing

• International Transfer Pricing Complex Variables

– Tax Factor

– Factor Tariff

– Power Factor Saings

– Environmental Risks

– Evaluation of Performance Factors

– Contribution Accounting

• Transfer Pricing Methodology

– Price vs. Cost vs. …..?

– Principle of Fair Price

– Method of Equivalent Rates Not Controlled

– Method of Controlled Transaction Not Equal

– Method of Selling Price Return

– Method of Determining the Cost Plus

– Comparable Profit Method

– Method of Separation of Income

– Other Pricing Methods

– Pricing Agreement Lajutan



• Practice Transfer Price

Each company is different from many dimensions. Usually every company running transfer

pricing practices as an obligation.

Many factors influence the transfer price. However, transfer pricing has 3 (three) main

objectives, namely:

A. Managing the tax burden (dominant)

2. Operational use of transfer pricing (to maintain the position of the company’s competitiveness,

promote the performance evaluation, motivating employees, managing inflation)

3. Manage risk and eliminate foreign exchange restrictions on cash transfers relative


Sumber : http://siswantari.wordpress.com/2012/05/19/bab-14-penetapan-harga-transfer-dan-perpajakan-internasional/


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