ANALISIS ECONOMIC BENEFIT DAN ARM’S LENGTH PRINCIPLE TERHADAP TRANSAKSI PEMANFAATAN JASA MANAJEMEN

Abstract

This research aimed to find out the process of economic benefit verification on transaction of management service utilization by multinational companies which focused on port service and arm’s length principles for service payment which had been used related to valid tax provision. The research was qualitative, in which the researchers examined on-going analysis, not examined hypotheses. Moreover, the research instrument used observation, field data collection, interviews, and documentation. The research result showed that some ways of affiliation in analyzing economic benefit on abroad legal existence were by examining its existence and service realization, having data proof and supporting legal documentation of legal existence, also in deciding arm’s length principle for service payment, it needed comparison data analyzing which related to criteria in order to be fulfilled whitin comparable analysis with the third database, i.e. Transfer Pricing catalyst. Another way was by deciding a proper Transfer Pricing, namely, cost plus method. Additionally, in this research economic benefit verification and arm’s length principle were applied in higher structured law enforcement and by comprehensively in considering its substance into tax court as the independent one.
Keyword: economic benefit, arm’s length principle, legal existence, transfer pricing, cost plus method