Perubahan Tarif Pajak Penghasilan Badan dan Pengaruhnya Terhadap Harga Transfer (Transfer Pricing) Apakah Perbedaan Tarif PPh Badan Menyebabkan Importir Melakukan Mark-Up atau Mark-Down Harga Transfer?

• Main Authors: , VINNA DIEN ASMADY PUTRI, , Prof. Tri Widodo, M.Ec.Dev., Ph.D.
• Format: Theses and Dissertations NonPeerReviewed
• Published: [Yogyakarta] : Universitas Gadjah Mada 2013
• Subjects: ETD
• Online Access: https://repository.ugm.ac.id/125768/; http://etd.ugm.ac.id/index.php?mod=penelitian_detail&sub=PenelitianDetail&act=view&typ=html&buku_id=65945
• Institution: Universitas Gadjah Mada

The rate of corporate income tax which is determined by each country creates a variation that allowing multi national companies to take advantage of the differences by minimize its global tax in order to maximize its global profit. This activity may include the use of transfer pricing activities by way of using mark-up or mark-down prices of goods transfers between affiliates located in different countries. Thus there will be transfer of income (income shifting) from companies located in countries with high corporate income tax rates to a country with lower corporate income tax rates. The rate gap between corporate income tax in one country and another is called transfer pricing incentives. Based on previous literature, a change in the transfer pricing incentive is significantly and positively influencing the transfer price of goods . This study will examine and analyze the effect of transfer pricing incentives on transfer prices of imported goods. The data used is panel data contains Indonesia�s import data, both the value and quantity, of goods from China, Japan, South Korea, Singapore and the United State, the data of corporate income tax rates, average imports tariff, gross domestic product per capita and inflation data from each of these countries within the period of 2005 to 2010. These datas are then processed using a Fixed Effect model analysis. The samples were taken from 70 groups of goods (classified by 2 -digit HS code). The results of this study showed that changes in corporate income tax rate significantly affect the reported transfer price of goods by importers in Indonesia, but the relationship is negative. This can be explain by the country samples. This study�s sample were taken from 5 countries where 3 of them have a higher tax rate than Indonesia so as to increase the company's global income, the multinational enterprises will be prefer to be taxed in Indonesia rather than in their home country.