Analisis Prinsip Kewajaran dan Kelaziman Usaha Terhadap Transaksi Afiliasi (Studi Kasus PT. ABC)

Abstract

This research to analyze the transfer pricing transaction method by PT. ABC with Associated Enterprise. This research also to analyze the transactions is in line the arm's length principle or not and to analyze the transactions is already in line with the tax regulation of indonesia PER 32 / PJ / 2011. 
The metode of this reseacrh is qualitative descriptive. Transactions analyzed in this research is a transaction by PT ABC with Associated Enterprise for the period 2016. The transaction will be analyzed is already in line with the tax regulation of 
indonesia PER 32 / PJ / 2011 and the OECD Guidelines transfer pricing or not.  The results of this research show that ABC Inc. used Transactional Net Margin Method (TNMM) as transfer pricing method of transaction with aaffiliated 
enterprise. After testing arm’s length principle with TNMM (Transactional Net margin Method),  ABC Inc. has profit level 30,52% for the period 2016. This is above the arm’s length range comparable company,than transaction by ABC Inc.  also in line with arm’s length principle. In applicating the arm’s length principle, ABC Inc. is already in line with the tax regulation of indonesia PER 32 / PJ / 2011