16
9月

Contoh Kasus Mutual Agreement Procedure

The meeting between the DJP and IRAS resulted in important progress with regard to the Mutual Agreement Procedure (MAGP) application and the Advance Pricing Agreement (APA) filed by Indonesian taxpayers and state partner taxpayers/courts. On that occasion, agreement was also reached on the settlement of two POPs cases. On the basis of the agreement contained in PMK No 39/PMK.03/2017 on procedures for the exchange of information under international agreements, it is explained that the competent authority, hereinafter referred to as an authorised official, is an official in Indonesia, in a partner country or in the jurisdiction of the partner empowered to carry out the exchange of information in accordance with the international convention. For example, I do not know if the Directorate-General for Taxation, of the Ministry of Legal Affairs and Human Rights, I have not found the answer. In many cases, international tax disputes are frequent due to differences between fiscus and taxpayers in the interpretation of multiple tax evasion agreements (P3Bs) or tax treaties and/or price transfers for transactions with related parties in different legal systems. . . .