ANALISIS PENERAPAN TAX TREATY PADA TRANSAKSI INTERNASIONAL

Abstract

This research aimed to analyze the level of compliance with tax obligations due to tax treaty policy implementation, its consistency during international transaction implementation, and its effect on the cost-saving. This research was descriptive-qualitative. Furthermore, the data were both primary and secondary. The primary data were taken from interviews with two informants in the international transaction. While the secondary data were in the form of documents related to tax treaty implementation. The result showed that: first, there was non-compliance with the fulfilment of tax administration on the tax treaty rate policy implementation on international transactions due to delays in submitting SKD/COD (Certificate of Domicile) documents by foreign taxpayers. It was submitted after tax reporting period. However, the tax treaty rate remains the basis for tax deductions. Secondly, the tax treaty rate policy was implemented consistently during 2015-2019 with the tax treaty rate as a basis for withholding tax on dividend income and submitting tax provisions on income from management services to the country of residence. Third, the tax treaty rate policy implementation was profitable for by taxpayer because by reducing the tax withholding rate, there was a cost saving on the difference in tax debt that would be paid by taxpayer. Therefore, these funds would be optimized through investment instruments.