Vol. 17 No. 2 (2024): Jurnal BPPK
No. 2 2024 Badan Pendidikan dan Pelatihan Keuangan
- Volume
- 17
- Nomor
- 2
- Tahun
- 2024
- DOI
- 10.48108/jurnalbppk.v17i2
Artikel (6)
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Articles
TAX CERTAINTY IN LIGHT OF TWO-PILLAR SOLUTION: THE ROAD TO INTERNATIONAL TAX ARBITRATION FOR INDONESIA?
Defi Defi (Directorate General of Taxes)
Abstrak
As one of the members of the OECD Inclusive Framework, Indonesia is participating the global consensus discussions on Pillar One and Pillar Two, where the signing of the Multilateral Convention of the Two-Pillar Solution is scheduled in 2024. One of the key elements, tax certainty, is designed with mandatory and binding dispute resolution mechanism that resembles to arbitration. Currently, Indonesia’s tax dispute resolution regime does not adopt arbitration mechanism. This article juxtaposes the international tax dispute resolution landscape (under the OECD Model and the UN Model, as well as under the EU Directive and the US Model) with the dispute resolution mechanisms that will be implemented under Pillar One and Pillar Two, which are ultimately reflected in the Indonesia’s tax dispute resolution. At the end of the article, it can be concluded that the tax certainty design adopted by the Two-Pillar Solution corresponds to mandatory and binding MAP arbitration, accordingly when the Multilateral Convention on the Two-Pillar Solution was signed, Indonesia entered a new era of the arbitration adoption in its international tax dispute resolution.
Kata kunci: two-pillar solution, tax certainty, dispute resolution, international taxation, oecd
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Articles
THE IMPACT OF DOWNSTREAM MINING-BASED INDUSTRIES ON THE ECONOMY OF SOUTHEAST SULAWESI PROVINCE
Winardi Winardi (Kementerian Perindustrian)
Abstrak
Industrial downstreaming through the development of industrial estates and smelters is a National Strategic Project (PSN), some of which are located in Southeast Sulawesi Province. The investment plan for the development of industrial estates and smelters is estimated to reach Rp 67.7 trillion. Therefore, it is necessary to conduct a study to analyze the role of industrial estate and smelter development on the economic performance of Southeast Sulawesi Province. The method used is the Final Demand Impact analysis of the Input Output (I-O) Table. The results of this study showed that the downstream industry contributed to an increase in output and value added to the economy of Southeast Sulawesi Province by 3 times as much as before and an increase in employment to around 4.5 million people. Based on the results of this study, a real justification is obtained that the downstreaming of industrial estate and smelter development plays an important role in encouraging the achievement of several national industrial development goals, namely increasing output, added value and employment through sustainable mining downstreaming.
Kata kunci: Hilirisasi industri, Kawasan Industri, Smelter, Sektor Industri, Investasi, Tabel Input Output
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Articles
THE ISSUE OF TRANSFER PRICING AND MULTINATIONAL ENTERPRISES IN INDONESIA: A NOTE TO TAX TRIBUNAL DECISION
MUHAMMAD DAHLAN (Direktorat Jenderal Pajak)
Abstrak
The growing trend of cross-border transactions conducted by multinational enterprises sheds new light on the consequences of transfer prices between affiliates among multinationals. This study aims to explore the battle between multinationals and the Indonesian tax authority, Directorate General of Taxes, concerning tax consequences of intra-group service arrangements as stipulated in three tax cases brought to the Indonesian tax court in 2021 and 2022. This study finds uses legal doctrine analysis as the methodology and finds that when scrutinizing the intra-group service transactions among members of multinationals, there was a lack of understanding from the Indonesian tax authority officers in applying the international transfer pricing guidelines and domestic tax regulations. From the tax judges’ perspectives, there was an inconsistency in applying tax regulations, mainly dealing with the administrative burden of proof to benefit intra-group service treaty provisions. This study contributes to the literature by establishing certainty that there is ambiguity in the provisions of the Indonesian tax legislation, which led to different interpretations from the tax officers, multinationals, and tax court judges
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Articles
FORECASTING MONEY SUPPLY USING GARCH METHOD FOR INDONESIA REDENOMINATION POLICY
Bintang Putri Aulia (Politeknik Statistika STIS), Khrisna Aji Pamungkas (Politeknik Statistika STIS), Lourna Mariska Mauboy (Politeknik Statistika STIS), Tyas Kurnia Wijayanti (Politeknik Statistika STIS)
Abstrak
The success of redenomination as a monetary policy depends on the country’s fundamental economic situation. Money supply, as one of the factors, indicates the occurrence of inflation, so it needs to be examined as a consideration for redenomination decision-making. Using the GARCH method, forecasting the money supply with the intention to determine its stability and Indonesia’s readiness for it. The data sourced from Bank Indonesia. It was found that a stable and consistent pattern of money supply (M2) each year concluded that Indonesia could potentially implement redenomination in time to come.
Kata kunci: Money Supply, GARCH, Forecasting, Redenomination
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Articles
STRATEGY FOR PREPARING CBDC IMPLEMENTATION IN NORTH SUMATRA
Akhmad Munim (BPS), Reni Amelia
Abstrak
This study aims to determine the characteristics and identify the factors that influence the people of North Sumatra who are adaptive to the implementation of CBDC. It is approached by people who access e-banking. We find that characteristics of people who are adaptive to the implementation of CBDC are college graduate; finished high school/equivalent and living in urban areas; and finished high school/equivalent, living in rural areas, and working in processing industries, finance, insurance activities, government administration, defense, compulsory social security, education, human health activities, and social activities. These findings suggest that the CBDC implementation should take into account individual characteristics.
Kata kunci: Classification and Regression Trees (CART), Resampling, CBDC, e-banking
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Articles
ANALISIS DAMPAK KEBIJAKAN RENEWABLE ENERGY DIRECTIVE (RED) II TERHADAP EKSPOR CRUDE PALM OIL INDONESIA TAHUN 2009-2023
Eris Girasto, Erwin Agung Nur Rohmat (Politeknik Statistika STIS), Rafael Agintha Tarigan, Riska Meyliana Sari, Nasrudin Nasrudin
Abstrak
Crude Palm Oil has become a crucial commodity for Indonesia, contributing significantly to the country's income. The European Union (EU) is one of the main export destinations for Indonesian CPO. However, in the past decade, the volume of Indonesian CPO exports to the EU has been declining due to the policies implemented by the EU Parliament. For instance, Renewable Energy Directive (RED) II, which restricts the entry of CPOs into the EU. This study aims to provide an overview of Indonesian CPO exports to the EU and assess the impact of the RED II policy on the volume of CPO exports from Indonesia. The study uses data from May 2009 to September 2023, covering the volume of Indonesian CPO exports to the EU. The ARIMA Intervention method was used in the research. The study indicates that RED II policy has a significant impact on Indonesian CPO exports to the EU.
Kata kunci: RED II Policy, Crude Palm Oil, ARIMA Intervention