| Summary: | This study aims to analyze the impact of the application of the rules of
arm�s length principle in the transaction between company/taxpayer to related
party, through the Director General of Taxation Regulation No. PER-43/PJ/2010
as amended by PER-32/PJ/2011 and how its application in a multinational
company, in this case in PT X as a subsidiary of a multinational company.
Included in this is to analyze the approach taken by PT X to prove the arm�s
length principle through the implementation of appropriate transfer pricing
documentation set out in the regulation and its impact on management control of
the Company.
Implementation of this regulation is important and good for benefit and
interests of government and corporate especially in providing guidance in
conducting transactions with related parties and its proof. Departing from the
transfer pricing issues in the globalization era of trade openness between
countries and business changes in the external environment with the
implementation of the regulations, limitation of the research conducted with case
study in PT X by descriptive analytics that provide an overview and
understanding of the impact of the regulation on the Company's policy approach
and analysis on the implementation of its transfer pricing documentation.
According to Anthony and Govindarajan (2007), transfer pricing policy in
a multinational company can be largely controlled by parent company or by
giving the decision on transaction and pricing on each subsidiary. Related to the
second policy as policy implemented in this study, PT X has a greater role in
management control to manage its transfer pricing pratices which in accordance
with the applicable regulations in its tax jurisdiction. In this case, the application
of transfer pricing documentation implemented by PT X with such proportionality
analysis, the use of comparative data, analysis of the functions performed, assets
used, risks exist, industry and economic analysis refers to the guidelines and
regulations, but the implementation is still limited for the purpose as a
communication media in the tax audits.
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