Authors:
Errine Nessy
and
Ning Rahayu
Affiliation:
University of Indonesia, Indonesia
Keyword(s):
Base Erosion and Profit Shifting (BEPS),
Hybrid Mismatch Arrangement,
Hybrid Financial Instrument,
Hybrid Transfer, Hybrid Entity
Abstract:
The purpose of this study is to find out the relevance of BEPS Action Plan 2 Recommendations with Indonesian domestic laws and obstacles if Indonesia adopts BEPS Action Plan 2 recommendations to its domestic laws. This study was conducted with a qualitative approach, with data collection through library and field study. The field study conducted through in-depth interviews with some key informants that represent practitioners, academics, and tax authorities in Indonesia. The result of this study shows that BEPS Action Plan recommendations that are relevant to be applied in Indonesia are Recommendation 1, Recommendation 4, Recommendation 8, Recommendation 2.2, and Recommendation 5.1. Meanwhile, the main obstacle in adopting BEPS Action Plan 2 recommendations in Indonesia is the level of complexity and difficulty in administering those rules. In applying the proposed linking rules, both the taxpayer and the tax authority should have detailed information about the tax treatment of instr
uments or entities in other jurisdictions.
(More)