ANALISIS PRINSIP KEWAJARAN DAN KELAZIMAN USAHA TERHADAP TRANSAKSI AFILIASI (STUDI KASUS PADA PT. ABC)

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Pamuji Sekar Sari
Suyono Salamun

Abstract

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.

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