Page 49 - InsideTax Edisi 38th (Aksi BEPS: Menangkal Penggerusan Basis Pajak)

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Memberikan sumbangsih bagi kemajuan ilmu pengetahuan khususnya di bidang perpajakan, merupakan komitmen yang selalu
dipegang teguh oleh DANNY DARUSSALAM Tax Center (DDTC).
DDTC kembali berpartisipasi dalam penerbitan sebuah edisi keempat buku The Tax Disputes and Litigation Review
terbitan Law Business Research Limited, penerbit yang menjadi pemenang di berbagai penghargaan dalam international business
law dan international legal markets.

uku ini ini akan membekali para praktisi pajak dengan kerangka
dasar isu sengketa pajak yang terjadi di berbagai yurisdiksi. Pada
Bedisi ke-4 ini, setiap babnya akan menyajikan kerangka hukum
terkait proses bersengketa dari tahap upaya administrasi sampai
upaya hukum di berbagai negara, termasuk Indonesia. Khusus untuk
Indonesia penulis dari Danny Darussalam Tax Center melengkapi
analisisnya dengan berbagai perkembangan terkini secara kebijakan
dan perkembangan putusan-putusan Mahkamah Agung terkait
penyelesaian sengketa perpajakan di Indonesia.

Chapter 16
Chapter 16
INDONESIA
Chapter 16
INDONESIA
Chapter 16
INDONESIA
David Hamzah Damian 1 Chapter 16
David Hamzah Damian 1
INDONESIA
David Hamzah Damian 1
INDONESIA Pesan e-book
David Hamzah Damian 1
David Hamzah Damian 1
I INTRODUCTION
I INTRODUCTION
INTRODUCTION
I
Tax disputes in Indonesia involve local government administration by the revenue
Tax disputes in Indonesia involve local government administration by the revenue
authority of the province and regency, and central government taxes administered by the
Tax disputes in Indonesia involve local government administration by the revenue
INTRODUCTION
authority of the province and regency, and central government taxes administered by the
I
authority of the province and regency, and central government taxes administered by the
Ministry of Finance through the Directorate General of Taxes (DGT) and the Directorate
INTRODUCTION
I
Ministry of Finance through the Directorate General of Taxes (DGT) and the Directorate
General of Customs and Excise (DGCE). Procedures for dispute resolution are governed
Tax disputes in Indonesia involve local government administration by the revenue
Ministry of Finance through the Directorate General of Taxes (DGT) and the Directorate
Tax disputes in Indonesia involve local government administration by the revenue
General of Customs and Excise (DGCE). Procedures for dispute resolution are governed
authority of the province and regency, and central government taxes administered by the
by the Local Tax Law at administrative level for local government taxes; by the Customs sekarang!
General of Customs and Excise (DGCE). Procedures for dispute resolution are governed
authority of the province and regency, and central government taxes administered by the
by the Local Tax Law at administrative level for local government taxes; by the Customs
by the Local Tax Law at administrative level for local government taxes; by the Customs
Ministry of Finance through the Directorate General of Taxes (DGT) and the Directorate
Law and the Excises Law for taxes administered by the DGCE; and by the General Rules
Ministry of Finance through the Directorate General of Taxes (DGT) and the Directorate
Law and the Excises Law for taxes administered by the DGCE; and by the General Rules
General of Customs and Excise (DGCE). Procedures for dispute resolution are governed
Law and the Excises Law for taxes administered by the DGCE; and by the General Rules
of Taxation Law (the GRT Law) for taxes administered by the DGT.
General of Customs and Excise (DGCE). Procedures for dispute resolution are governed
of Taxation Law (the GRT Law) for taxes administered by the DGT.
by the Local Tax Law at administrative level for local government taxes; by the Customs
of Taxation Law (the GRT Law) for taxes administered by the DGT.
by the Local Tax Law at administrative level for local government taxes; by the Customs
The number of tax disputes filed for resolution in the Tax Court for 2014 amounted
Law and the Excises Law for taxes administered by the DGCE; and by the General Rules
The number of tax disputes filed for resolution in the Tax Court for 2014 amounted
Law and the Excises Law for taxes administered by the DGCE; and by the General Rules
The number of tax disputes filed for resolution in the Tax Court for 2014 amounted
to 10,866 applications, increased by 29.37 per cent compared with 2013 tax disputes
to 10,866 applications, increased by 29.37 per cent compared with 2013 tax disputes
of Taxation Law (the GRT Law) for taxes administered by the DGT.
to 10,866 applications, increased by 29.37 per cent compared with 2013 tax disputes
of Taxation Law (the GRT Law) for taxes administered by the DGT.
applications. 2 Tax Court Decisions issued in 2014 is 8,845 increased by 19.92 per cent
applications. 2 Tax Court Decisions issued in 2014 is 8,845 increased by 19.92 per cent
applications. 2 Tax Court Decisions issued in 2014 is 8,845 increased by 19.92 per cent
The number of tax disputes filed for resolution in the Tax Court for 2014 amounted
The number of tax disputes filed for resolution in the Tax Court for 2014 amounted
to 10,866 applications, increased by 29.37 per cent compared with 2013 tax disputes
compared to 2013. The large number of tax disputes filed for resolution in the Tax Court
compared to 2013. The large number of tax disputes filed for resolution in the Tax Court
compared to 2013. The large number of tax disputes filed for resolution in the Tax Court
to 10,866 applications, increased by 29.37 per cent compared with 2013 tax disputes
applications. 2 Tax Court Decisions issued in 2014 is 8,845 increased by 19.92 per cent
applications. 2 Tax Court Decisions issued in 2014 is 8,845 increased by 19.92 per cent
is the result of enforcement of official assessment in Indonesia when an assessment result
is the result of enforcement of official assessment in Indonesia when an assessment result
is the result of enforcement of official assessment in Indonesia when an assessment result
compared to 2013. The large number of tax disputes filed for resolution in the Tax Court
compared to 2013. The large number of tax disputes filed for resolution in the Tax Court
is deemed incorrect by a taxpayer where 45.12 per cent of Tax Court Decisions fully in
is deemed incorrect by a taxpayer where 45.12 per cent of Tax Court Decisions fully in
is deemed incorrect by a taxpayer where 45.12 per cent of Tax Court Decisions fully in
is the result of enforcement of official assessment in Indonesia when an assessment result
is the result of enforcement of official assessment in Indonesia when an assessment result
favour of taxpayers, 16.17 per cent partially in favour of taxpayers, and 27.57 per cent
favour of taxpayers, 16.17 per cent partially in favour of taxpayers, and 27.57 per cent
is deemed incorrect by a taxpayer where 45.12 per cent of Tax Court Decisions fully in
favour of taxpayers, 16.17 per cent partially in favour of taxpayers, and 27.57 per cent
denied the request from taxpayer. The amount of tax disputes carried over to civil review
is deemed incorrect by a taxpayer where 45.12 per cent of Tax Court Decisions fully in
denied the request from taxpayer. The amount of tax disputes carried over to civil review
favour of taxpayers, 16.17 per cent partially in favour of taxpayers, and 27.57 per cent
denied the request from taxpayer. The amount of tax disputes carried over to civil review
favour of taxpayers, 16.17 per cent partially in favour of taxpayers, and 27.57 per cent
requested at the Supreme Court in 2014 is 1,162 cases, the largest among 2,617 total
requested at the Supreme Court in 2014 is 1,162 cases, the largest among 2,617 total
denied the request from taxpayer. The amount of tax disputes carried over to civil review
requested at the Supreme Court in 2014 is 1,162 cases, the largest among 2,617 total
denied the request from taxpayer. The amount of tax disputes carried over to civil review
cases. 3 Typically, increased official assessment is caused by a high tax revenue target. In
requested at the Supreme Court in 2014 is 1,162 cases, the largest among 2,617 total
cases. 3 Typically, increased official assessment is caused by a high tax revenue target. In
cases. 3 Typically, increased official assessment is caused by a high tax revenue target. In
requested at the Supreme Court in 2014 is 1,162 cases, the largest among 2,617 total
cases. 3 Typically, increased official assessment is caused by a high tax revenue target. In
cases. 3 Typically, increased official assessment is caused by a high tax revenue target. In
The
1 David Hamzah Damian is the partner of tax compliance and litigation services at Danny
David Hamzah Damian is the partner of tax compliance and litigation services at Danny
1
Darussalam Tax Center.
1 David Hamzah Damian is the partner of tax compliance and litigation services at Danny
Darussalam Tax Center.
1
1 David Hamzah Damian is the partner of tax compliance and litigation services at Danny
2
www.setpp.depkeu.go.id/Ind/Statistik/StatBerkas.asp. Accessed on 13 December 2015.
David Hamzah Damian is the partner of tax compliance and litigation services at Danny
Darussalam Tax Center.
www.setpp.depkeu.go.id/Ind/Statistik/StatBerkas.asp. Accessed on 13 December 2015.
2
3
Darussalam Tax Center.
Darussalam Tax Center. http://kepaniteraan.mahkamahagung.go.id/statistik-perkara/kinerja-penangana Law Reviews
www.setpp.depkeu.go.id/Ind/Statistik/StatBerkas.asp. Accessed on 13 December 2015.
2
http://kepaniteraan.mahkamahagung.go.id/statistik-perkara/kinerja-penangana
3
2
n-perkara-2014/1136-keadaan-perkara-peninjauan-kembali-tahun-2014.
www.setpp.depkeu.go.id/Ind/Statistik/StatBerkas.asp. Accessed on 13 December 2015.
n-perkara-2014/1136-keadaan-perkara-peninjauan-kembali-tahun-2014.
http://kepaniteraan.mahkamahagung.go.id/statistik-perkara/kinerja-penangana
3
2 www.setpp.depkeu.go.id/Ind/Statistik/StatBerkas.asp. Accessed on 13 December 2015.
http://kepaniteraan.mahkamahagung.go.id/statistik-perkara/kinerja-penangana
3
187
3 http://kepaniteraan.mahkamahagung.go.id/statistik-perkara/kinerja-penangana
n-perkara-2014/1136-keadaan-perkara-peninjauan-kembali-tahun-2014.
n-perkara-2014/1136-keadaan-perkara-peninjauan-kembali-tahun-2014.
187
n-perkara-2014/1136-keadaan-perkara-peninjauan-kembali-tahun-2014.
187 187
187
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