MENYIKAPI HUBUNGAN ISTIMEWA DAN PERKEMBANGAN
TERAKHIR TRANSFER PRICING DI INDONESIA
Dosen Program D3 Akuntansi Politeknik LP3I Bandung
“ A comparison between conditions ( including prices, but not only prices ) made or imposed between associated enterprises and those which would be made between independent enterprises , in order to determine whether a re-writing of the accounts for the purposes of calculating tax liabilities of associated enterprises is authorised under
Article 9 of the OECD Model Tax Convention “
Brief History The OECD has published the following report dealing with transfer pricing issues ;
- 1979 : Transfer Pricing and Multinational Enterprises.
- 1984 : Transfer Pricing For Multinational Enterprises – Three Taxation Issues.
- 1987 : Thin Capitalization .
- 1993 : Tax Aspects of Transfer Pricing within Multinational Enterprises The United States Proposed Regulation.
- 1995 : Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations ( update in 1996, 1997 , 1998 , and 1999 ) hereinafter OECD Guidelines.
- 2010 : OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
Keywords : Organization For Economic Co-Operation and Development ( OECD )