Abstract
This study seeks to find the meaning of transfer pricing of tax actors, namely Taxpayers and tax authorities, as well as tax consultants on tax disputes in Indonesia. The study was conducted using an interpretive approach and Ricoeur hermeneutical methods. Ricoeur's hermenutics method is carried out through three stages of analysis, namely the semantic stage, the reflection stage, and the existential stage. Analysis was carried out on the text, both written and unwritten. The written text is in the form of tax regulations related to transfer pricing, while the unwritten text is a dialogue in the transfer pricing dispute trial in the tax court and the results of interviews with taxpayers and tax consultants. Based on the three stages of Ricoeur hermeneutical analysis, the meaning of transfer pricing was obtained from three perspectives, namely the Taxpayer's perspective that interpreted transfer pricing as an effort to maximize company profits, whereas from the tax authority perspective transfer pricing was a potential loss of state revenue. In addition, the meaning of transfer pricing was also found from the perspective of a tax consultant as a form of the company's business strategy. The meaning of transfer pricing is then constructed in a stakeholder theoretical framework. Keywords:   transfer pricing, hermeneutics, Ricoeur, company profits, state revenues, tax avoidance, and stakeholders.
Highlights
Transfer pricing is part of a business and tax activity that aims to ascertain whether the prices applied in transactions of related party have been based on the arm’s length principle
Transfer pricing is a picture of the reality of the international taxation system that has an impact on the domestic taxation system of countries in the world
It is known that a company model with a decentralized system has the characteristics of an affiliate transaction in transfer pricing, where the transaction occupies the main position in tax investigation because a large number of countries believe that tax revenues have been lost very much due to the "transfer pricing black" through incorrect accounting practices (Mehafdi, 2000)
Summary
Transfer pricing is part of a business and tax activity that aims to ascertain whether the prices applied in transactions of related party have been based on the arm’s length principle. Ricoeur's hermeneutics approach is in accordance with the context of the research that seeks to interpret the experiences and events experienced by the informants in the transfer pricing dispute in the tax court to explore the meanings contained therein. Understanding of the element of authority can be seen from the point of view of the Directorate General of Taxes who has the duty to supervise and evaluate taxpayer compliance with regulations relating to transfer pricing Conditions that affect this understanding indicate that all interpretations occur in language and are raised by humans in a particular historical community. Written texts in the form of tax regulations and OECD TP Guidelines and unwritten texts in the form of interactions and dialogues in the trial will always have dialectics to bring up various kinds of discourse The existence of this discourse will be conducted by research informants (distortion) so that they can objectively understand existing transfer pricing disputes. The three stages of Ricoeur hermeneutics are a framework for analyzing research data which can be explained in the following figure
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