Munadia
Anastasia Prisella
Neni Maulidah
Mirdah
CHAPTER I
INTRODUCTION
A.
BACKGROUND
The
world is now a single market. Raw materials, labor and technical skills
come from all over the world. Similarly, markets for
products and services
are now also transnational.
This is because the business environment
is changing rapidly,
both domestically and globally. This change requires rapid
movement of business people to
immediately undertake a process of adaptation or adjustment to follow
the motion of the pace of change
is changing business environment so as not to
miss and can develop into much more than
the original.
In
the world of mining, of PT Adaro Energy is very familiar. Because the company
is already well known as a producer of thermal coal in Indonesia is second,
single coal miner in Indonesia, and one of the world's premier supplier of
thermal coal to market global seaborne. But in 2008, PT Adaro Energy is related
to a problem that cost the state by dragging and transfer pricing. In the
practice of transfer pricing, PT Adaro sells its coal to its affiliated
companies, Coaltrade Services International Pte. Ltd is located in Singapore
and in person it is very detrimental to the country because of the sales
practices of PT Adaro has manipulated tax evasion and royalties to the state
with a transaction that is not fair (not according to the price of coal on the
market).
Transfer
pricing practices were once only done by
the company solely to assess the performance of the divisions among the members or firm, but along with the times of transfer pricing
practices are also often used for tax management is an
attempt to minimize
the amount of tax to be paid.
Transfer
pricing is done
by PT Adaro
Energy tough revealed.
Because at that time, Indonesia does not have
a standard price of coal sold
commonly used. The
absence of standard prices
make it difficult to determine whether the rates imposed
under the standard or not. In this case, PT. Adaro Indonesia (Adaro
Energy PT) suspected
of selling coal at below market
prices to affiliated companies
in Singapore in
2005 and 2006. But then sold again in the market according
to the market price.
This is intended to avoid the royalties paid to the state.
Adaro
issue has been a
concern that the prodding of
House of Representatives Commission
VII Department of Energy and Natural
Resources (EMR) to investigate the case.
B.
PROBLEM
FORMULATION
1. What is the result
of transfer pricing
by PT Adaro Energy to the state?
2. What causes
the transfer pricing by PT Adaro Energy's
difficult to prove?
3. What sanctions should be imposed
on the irregularities committed by PT Adaro Energy?
4. How is the government's efforts to prevent transfer pricing cases going
back?
C.
OBJECTIVE
OF THE WRITING
1. To know the result of
transfer pricing by PT Adaro Energy to the state.
2.
To
determine the cause of transfer pricing by PT
Adao Energy is
hard to prove.
3. To determine which sanctions
should be imposed on the irregularities committed by PT Adaro Energy.
CHAPTER II
DISCUSSION
A.
PARTINENT
IDEAS
1.
Corporation
(PT)
PT is a statutory body established under the agreement that do business with
the entire tertetu
capital divided into shares and meet the requirements set forth in the statute and its implementing regulations.
Legal basis for the establishment of
PT, are as follows:
a. Close
PT, by Act 1
of 1995 on Limited Liability Companies.
b. Open
PT, under Law No.1/1995 and Law No. 8 of 1995
on Capital Market.
c. PT domestic investment, by Act 6 of 1968 in conjunction with Law 12 of 1970 on Domestic Investment.
d. PT PMA, based on Law No. 1
of 1967 in conjunction with Law No.11 of 1970 concerning Foreign Investment.
e. PT (Persero), under Law No.9/1969
on Establishment of
State and Government Regulation 12
of 1998 on the Company.
Classification of
PT visits from
holding stock mutual
relations, are as follows:
a. Holding
Company is
a company that has one or more other companies, and control through voting
rights on the basis of the percentage of shares in each company concerned; generally,
the parent company has its own business; however, if the parent company does
not have a separate business, parent company as it is a group company (holding
company) is also called the parent company.
b. Subsidiary
) is a company controlled by another company (called
the parent company).
c. Affiliated
Company is a company which is effectively controlled
by another company, or affiliated with the
company or some other company because of interest or ownership
or the same board.
2.
Definition
of Transfer Pricing
Organization
for Economic Co-operation and Development (OECD) defines transfer pricing as the
price specified in the transactions between group members in a multinational
company in which a specified transfer price can deviate from the fair market price
for his group throughout the match. They can deviate from the fair market price
for their position within the state is free to adopt any appropriate principles
for corporate.
Simamora
in Yeni Mangonting
(2000: 70), transfer
pricing is defined as a special selling price
used in the exchange of inter-divisional division recorded revenues for the
seller (selling division) and the division of costs
buyers (buying divison).
Transfer pricing is often also
referred to as intracompany pricing, intercorporate pricing, interdivisional or
internal pricing are prices calculated for the purposes of management control
over the transfer of goods and services among members (group of companies).
Transfer pricing is usually set for products between (intermediate product)
which is the goods and services supplied by okeh division seller to buyer.
When
examined it further, transfer pricing can deviate significantly
from the agreed price. Therefore
transfer pricing is also often associated with a
systematically engineered prices that are aimed
at reducing the profits will reduce the amount
of taxes or duties of a country.
3.
Goals
of Transfer Pricing
Simamora
in Yeni Mangonting
(2000: 71) states
that the purpose of transfer pricing is to transmit financial data among departments or
divisions, the company filled in each time they use the
goods and services with each other.
Besided
that goals, Ronen and McKinney in Yeni Mangonting (2000:
71) also states
that transfer pricing is
sometimes used to evaluate the performance of the division and the division
managers motivate sellers and buyers
to the division decisions
are compatible with the overall corporate goals. A transfer pricing system should satisfy
three objectives: acurate performance evaluation, goal congruence, and
preservation of divisional autonom.[1]
While
Hansen and Mowen
in Yeni Mangonting
(2000: 71) states
that within the scope of multinational
companies, transfer pricing is
used to, minimize the taxes
and duties that
they incur throughout the world.[2]
4.
Methods
of Transfer Pricing
Several
transfer pricing methods are often used by corporations and conglomerates
divisionalisasi / departmentation is:[3]
a. Cost-Based Transfer Pricing.
Companies that
use the transfer method
to the cost of setting the transfer price
variable and fixed
costs that can be
in 3 forms, is : full cost, full cost plus markup and variable
cost plus fixed fee.
b. Market Basis Transfer Pricing.
If there is a perfect market,
transfer pricing method based on the market price of these is the most appropriate
measure because it is independent. However, the limited market information that
is sometimes an obstacle in the use of transfer pricing is based on market
prices.
c. Negotiated Transfer Prices.
d. In the absence of prices, some
companies allow the divisions within the company with an interest in transfer
pricing to negotiate a transfer price desired. Negotiation transfer price
reflects controliability perspective inherent in the centers of responsibility
for each division are concerned that in the end that will be responsible for a
negotiated transfer price.
5.
Transfer
Pricing in Multinational Companies
There
are two objectives/goals to be achieved transfer pricing by multinational companies is:[4]
a. Performance Evaluation.
One of the ways
used by many companies
in assessing what level of performance is to
calculate its ROI or Return On Investment.
Sometimes the level of ROI for a division
with other divisions
within the same
company are different from one another.
For
example, division sellers want a high transfer price which will increase
income, which will automatically increase their ROI, but on the other hand, the
division buyers demanding a low transfer price which will result in an increase
in income, which means also an increase in ROI. This sort of thing is what
sometimes makes transfer pricing that is wedged position. Therefore, to
overcome this problem, the parent company would be very interested in transfer
pricing.
b. Optimal Determination of Taxes
Tax
rates between one country to another different.
This difference is caused by the economic, social, political,
and cultural force in the country. Africa
for example, due to the low level of investment,
the applicable tax rate in the country is low. But
if we are talking about America, it is unlikely that the tax rate applicable
in the country are the same as in the African country.
It is clear, as
in developed countries like America
very high level
of investment, as evidenced by
the growth rate of the enterprise is increasing. On this basis the tax
rate is set high in the country concerned.
6.
Transfer
Pricing in Indonesia
The
transfer pricing practices could result in a transfer of income or tax base
and / or the cost of a taxpayer to another
taxpayer, which can
be engineered to reduce the
overall amount of tax payable on
the taxpayer-taxpayer who has such relationship. Actually
lack Multimorbidity that could arise
because of the practice of transfer
pricing can occur between domestic taxpayers or the State Taxpayers with foreign parties, particularly those domiciled in Tax Haven Countries (countries that do not levy / tax levy is lower
than Indonesia) .
Directorate General of Taxation, through the Director General of Taxation
Circular N0. SE-04/PJ.7/1993
on March 3, 1993 states that lack Multimorbidity from
the practice of transfer pricing may occur on:
1) the sales
price;
2) the purchase
price;
3) The allocation of
general and administrative costs (overhead cost);
4) The imposition of
interest on a loan by shareholders (shareholder loan);
5) Payment of
commissions, licenses, franchises, leases, royalties,
compensation for management services,
engineering services and return for
exchange for other services;
6) Purchase of
property by the company's
shareholders (owners) or a related party
which is lower than
the market price;
7) Sales to
foreign parties through
a third party that is less / have no
business substance (example dummy
company, letter box company or reinvoicing center).
The following will
be given some examples
of cases that
causes less-fair arising from
the practice of transfer pricing,
are as follows:[5]
1.
Less-fair
Sales rice
PT A has a 25% stake in PT B. The
delivery of goods to the PT A to PT B,
PT A imposes a selling
price of Rp. 160.00 per unit, in contrast to the
price calculated on the transfer of
the same item to PT X (no relationship)
is Rp. 200.00
per unit. In the
example above, the
market price of comparable
(comparable uncontrlled price) on the same item
is being sold to
PT X is no
special relationship. Thus a reasonable price (arm's length price) is Rp. 200.00 per unit.
Price is used
as the basis for calculating income
and / or tax.
2.
Less-fair of Purchase Price
Hong Kong
H Ltd owns 25%
of PT B. PT B
importing goods produced H Ltd. at a price of
$ 3000.00 per unit.
The products were sold to PT Y (no relationship) at a price of Rp. 3500.00 per unit. In the example above,
first of all look comparable market prices
for the same item, or a similar kind
on the purchase / import of existing
parties or the special
relationship between the parties that there is no special
relationship. If the difficulties has been found,
then the selling price minus the approaches can be applied, ie by subtracting
gross profit (mark-up) plus reasonable other expenses incurred from the
taxpayer to the selling price of goods that do not have a special relationship.
If
reasonable profit obtained is Rp. 750.00 then, fiscally reasonable prices for
the purchase of goods from H Ltd. Hong Kong is Rp. 2750.00 (U.S. $ 3500.00 -
USD 750.00). The price of a basic calculation of the cost difference PT B and
Rp. 250.00 between debt payments to H Ltd Hongkong with the cost of it should
be taken into account as a disguised dividend payments.
3.
Less-Fair allocation of general
and administrative
expenses (overhead cost)
Head
office of permanent overseas in
Indonesia often allocate
general and administrative costs (overhead
costs) to the
BUT. Allocated costs
include:
a. Trainier
expense for employers BUT in Indonesia that celebrated kantor pusat di luar
negeri;
b. Travel expenses
to the directors of the central office
of each BUT;
c.
Administrative
costs / other management from a
central office running
costs of the company;
d. Costs
incurred research and development head
office..
The allocation
of these costs over the allowable benefits
comparable to each permanent and not a
duplication of costs.
4.
Less-Fair charging interest
on a loan
by a shareholder.
H
Ltd. in Hong Kong
has a 80% stake
in PT C with a capital that has not been paid Rp
200 million. H Ltd also provide a loan
of USD 500 million with an interest rate of 25% or Rp 125 million a year. The
prevailing interest rate is 20%.
In connection with the above transactions, are required to determine
the amount owed back PT C. Loan of USD 200 million is considered as the capital of disguise, so the amount of debt
that can be
recognized PT C amounted to USD 300 million (USD 500 million
- USD 200 million).
Interest expense that
may be imposed on the borrowing
and lending transactions above
is Rp 60 million
(20% x Rp 300 million), which means there is a positive correction.
5.
Less-fair of commission
payments, licenses, franchises, leases, royalties,
compensation for management services,
engineering services and compensation
for other service fee.
PT A computer company, to
license to PT X (no relationship) as
the sole distributor in country X to market the computer
program by paying a 20% royalty on net sales. Additionally
PT B in country B (no special relation) as the sole distributor and
pay a royalty of 15% of net sales. Transactions above the royalty
PT B also had 20%. This is
because the computer program
that is marketed by PT B is equal to that marketed
PT X.
6.
Purchase
of property by the company's shareholders
or by a related
party at a price lower
than the market price.
PT
A holding 50% of PT B stocks. Property company PT B form A vehicle purchased at
a price of Rp 10 million. The book value of the vehicle is USD 10 million. The
market price of similar vehicles in the same state Rp 30 million. From the
above transaction can be seen that the market price of the vehicle is
comparable to Rp 30 million, the taxable income of the positive corrected PT B
Rp 20 million (USD 30 million - USD 10 million). As for a difference in price
of USD 20 million is in the form of dividend income by PT B should cut income tax
article 23.
7.
Sales
to foreign parties through a third
party that has no business
substance (letter box company).
P PT I in Indonesia which
has a special relationship with H Ltd. in Hong Kong, two
of them is the subsidiary K in Korea. In its PT I export goods directly
delivered to the X
in the United States at the request of H Ltd.
in Hong Kong. The
cost of goods is Rp
100 and PT
in Indonesia I
always charge a
price of Rp 110. Moderate H Ltd Hongkong charge X
in the United States. The information
obtained from the United States
shows that X buys
goods at a price of Rp 175.
For the next information to
indicates that H
Ltd Hongkong just a Letter Box Company (reinvoicing
center) without business
substance. Because of Hong Kong's tax rate is
lower than in Indonesia, then there
is a hint of any attempt to divert taxpayer
taxable profits from Indonesia to Hong Kong
in order to obtain n tax savings.
Having regard to the function (business substance) of
H Ltd Hongkong,
then intermediaries such transactions (for tax
calculation) is considered non-existent,
so the selling price in Indonesia PT I
correctued by USD 65 (USD 175 - USD 110).
B.
DISCUSSION
1.
As
a result of transfer pricing by PT Adaro
Energy to the state
PT
Adaro Indonesia (PT Adaro Energy Tbk) is the second largest coal producer in
the country which has a flagship product Enviro Coal, low-calorie coal and
environmentally friendly. Companies which have coal reserves reach 928 million
tonnes with an area of 34 940 hectares of the previous mining conglomerate
Tanoto. But, due to the collateral Deutcshe Bank, the company was later bought
by a consortium of Indonesian businessmen cheap prices. The consortium, in
which Edwin Soryadjaya, Uno Uno S, Teddy Rachmat and Garibaldi Boy Thohir who
is now the Managing Director of PT Adaro Indonesia.
PT Adaro Indonesia suspected of committing tax evasion and
royalties to the state by way of transfer pricing. Therefore, Adaro
manipulation of tax evasion by buying and selling coal unnatural (not in
accordance with the international market price of coal) to its affiliated
companies Coaltrade Services International Pte. Ltd. of Singapore.
Seven
years ago, Adaro entered into an agreement with Coaltrade Services
International Pte Ltd, a company paper (paper company) in Singapore. The
agreement states that the Adaro coal sold per year at a price and under the
prevailing price in the market. Coaltrade and sell at international prices. Who
sold not just any coal, but high-grade coal.
In 2005,
Adaro sells to companies
Coaltrade of Singapore
at U.S. $ 26 per
ton, while the market
price of U.S. $
48 per ton. Whereas in 2006, Adaro
sells to Coaltrade U.S. $ 29 per ton, while the international
price of U.S. $ 40 per ton. With 2005 sales volume
reached 26 million tons over 2006 and
reached 34 million tons, there is a difference
between the selling price and the selling price to the international Coaltrade respectively U.S. $
589.9 million (Rp 5, 8 trillion by 2005 average exchange rate of Rp9.800 / U.S. $) in 2005 and U.S. $ 363.1
million (Rp3, 3
trillion, with the
average exchange rate in 2006 Rp9.096/US
$) in 2006.
If
calculated based on market prices, total
revenue in 2005 should
amount to U.S. $
1.287 billion in 2006 and U.S. $ 1.371 billion.
Means, there is a difference Adaro sales to sales
based on market prices. If in rupiahs reached Rp
9.121 trillion. Not
to mention the potential loss
of state royalties
ranging from 13.5% the value of Rp 1,231 trillion.
As a result of
transfer pricing that occurred in 2005-2006 and
an estimated Rp 9
trillion from the
sale of the hidden. So that losses related
state taxes and royalties
estimated at Rp 4-5
trillion. Royalties are to be paid
according to the value of the
sale price. The alleged transfer
pricing that decreases the value
of sales resulting in taxes and royalties to be paid automatically also fell. In addition, transfer pricing
by PT Adaro also indirectly impacted due to the poor people who live in the mine
due to the presence
of such deviations PT Adaro also have taken
away the right of people to
obtain government should fund the
development of the share of the payment of taxes
and royalties the.
2.
Cause of transfer pricing
by PT Adao Energy difficult to prove
Transfer
pricing by PT Adaro
was actually started
in 2007 due to sticking
battle Tanoto conglomerate
with Edwin Soeradjaya
Cs. From there comes the alleged PT Adaro
Indonesia coal sold
at below market prices to its affiliated
companies in Singapore, Coltrade PTC Services
International, Ltd. in 2005
and 2006. By Coltrade,
coal was then
sold again to the
appropriate market price of the market. This
is intended to avoid the payment
of royalties and taxes that should be
paid to the state treasury.
This
case was originally reported by the Department of Energy and the Director
General of Taxation to the Attorney General, so that this case was handled AGO
(Attorney General). But along with the investigations that have been carried
out, finally AGO itself has stopped the transfer pricing investigation PT Adaro
Indonesia. According to him, this case is already completed and there is no
problem in it and conclude that PT Adaro himself has paid all royalties and
taxes that pointing.
It is very
troubling the hearts of members of the House of Representatives
Commission VII, so
they are proposed for the formation of the Special Committee to investigate the coal directly on the case, because
they considered that the Attorney General has not been incompetent in handling this case. Because
transfer pricing case that this happens,
so quaint and intricate
investigation and must be done carefully and
thoroughly.
Complexity of
these cases occur because the two
companies affiliated with cleverly doing financial
engineering by exploiting regulatory
weaknesses in Indonesia
that is still of profanity (in this case the price of standard coal in
Indonesia is still uncertain). Simply put, the model measures
the irregularities done is to utilize other
firms in the Singaporean and other countries, such as Mauritius and Virgin
Island, a favorite place for Indonesian conglomerate to commit money
laundering (money laundering).
Both
companies manipulate tax evasion by selling
coal traksaksi improperly
(does not match the price of coal on the
international market) with
argue to fluctuations in commodity prices. If referring to the available data, clearly states harmed
in this case.
Losses
due to the country's transfer pricing case is
the implication of weakness in
terms of national taxation system. Because
once I figure poorer until in 2008 the government
does not have any guidelines on transfer pricing or tax
could also indicate
avoidance.
Proof against manipulation attempts indication that
price is indeed
very difficult. No explanation
of how
and technical mode is
very easy, but it's
proving very difficult through the
document. This
game can
not be proved
if only examined
from ordinary
accounting audit mechanism which
is conducted every
year by
the company concerned.
Therefore, in their
search efforts
need mechanisms investigative audit.
3.
Sanctions should
be
imposed
on
the
irregularities
committed by PT
Adaro
Energy
In the case of transfer
pricing taxation
enters this region, is
likely to be
completed without
any further
investigation. Due in
mid-2008, Directorate General Taxation Nasution said, Adaro has
been called
and admitted mistakes on
tax and royalty
companies.
Adaro also agreed
to pay
the tax deficiency, but not be
fined based
on sunset
policy. In fact,
since the beginning
of sunset policy
program for the
removal of sanctions
for individual
taxpayers who
voluntarily sign
up to
obtain TIN in
2008. So,
not intended
for institutions
or bodies, especially in large
scale enterprise
financial calculations have
the ability
to pay
a tax
penalty. It's also a
big question
as Adaro floor plans in
the capital market.
When viewed from
the side of the law,
because transfer
pricing tax evasion
that has
deviated from
the applicable tax
provisions, because
the substance
of the state should
be able mempajaki multinational companies in larger
quantities. Thus
do companies that will
be subject to
criminal sanctions taxation, to Indonesia in
accordance with
Law No. 16
of 2000 provided for in Article 39, that
a tax
crime would be
punishable by
imprisonment of six
(6) years and a fine
high 4 (four) times
the amount
of tax payable is not paid
or underpaid.
The difference between tax
avoidance with
tax evasion is
very thin
and the
business ethics
of the transfer
pricing practices
can lead
to moral hazard,
because contrary
to applicable regulations.
In addition, the
Court per-taxation assessed a comprehensive
solution to
resolve tax cases, including allegations
of transfer pricing
tax-manipulation
performed a
number of companies,
also Asian
Agri business group.
Because the
problem of transfer pricing has
not been
criminally prosecuted, because
the actual tax purposes
is not punishing people but that money or
the right of the state is
not manipulated.
In the Tax
Act article 18
paragraph 3 also confirmed the
tax issue
is not included
in the criminal
realm.
4. Government
efforts
to prevent transfer pricing cases occurred back
Transfer
pricing is certainly very detrimental to the state, so as soon as possible as
a responsible government of
the state itself must act quickly in respon
and overcome. Also
required the government's seriousness in dealing with taxes and royalties to the state,
because indirectly, if the country loses, then
the impact will also be influence
for the country's own citizens. So that, we
need the efforts of the government to transfer
pricing cases as that of PT Adaro does not
happen again. One,
the government's efforts to prevent
transfer pricing is adding DG Taxation authority
to correct the mutual agreement between the taxpayer of the Interior (WDPN) with their
counterparts abroad. Correction is
done when there is an indication of inaccuracy of information or documents
submitted by WPDN Indonesia and their partners. [6]
This
provision is contained in
Article 19 of Regulation Directorate
General of Taxation Number Per-48/PJ/2010
on Procedures for Joint Implementation Agreement Procedure (Mutual Agreement
Procedure) Based on Avoidance of Double Taxation (P3B). Beleid effective from 3
November 2010.
P3B an
agreement between the Government of
Indonesia with the
state government or partner jurisdictions to
prevent double taxation and
tax evasion. However, the above efforts will only prevent transfer pricing, and not necessarily to
increase tax revenue for the
state. however, it depends
on the method and
the quality of the correction itself Taxation
Office. The details, appropriate penalties for perpetrators of
transfer pricing should also keep running, because
that's where one of the tax revenue for the
state as compensation from
the embezzlement occurred.
CHAPTER III
CONCLUSION AND
SUGGESTION
A.
CONCLUSION
1. Talking about
taxes and royalties,
which is normally found in each person's mind
is this is an
obligation that must be paid
to the State as a form of responsibility and aspirations of a
people. However, there
are those who assume that the
payment of taxes and
royalties to the state is something that is very difficult, so there was
a deviation in the form of
transfer pricing cases. One of its associated companies
is PT Adaro
Energy. This case
is very detrimental state, let alone the number has reached trillions. In addition to the state, people who live in the mine area
was also not
miss out the case
due to the development fund.
2. Transfer pricing
cases oeh PT
Adaro is very
difficult to accomplish. Because the government did not have a standard price in
the sale of coal, so that although the mode that
was already known,
but the proof is very hard to do.
3. In the case of
transfer pricing is, in the end Adaro also
admitted that the company had meakukan
irregularities. Adaro also agreed to pay
the tax deficiency, but not be fined
based on sunset
policy. In fact, since the
beginning of sunset policy program for the removal
of sanctions for individual
taxpayers who voluntarily sign up to obtain
TIN in 2008. So,
not intended for institutions
or bodies, especially in large scale enterprise financial calculations have
the ability to pay a tax penalty.
4. Transfer pricing
case is a case that is very detrimental to the state. And if this occurs, then
increase the country's
foreign exchange deficit will be
even longer. And to prevent this, the government has endeavored to prevent
the occurrence of this case, by adding the Directorate
General of Taxation authority to
correct the mutual agreement between
the taxpayer of the Interior (WDPN)
with their counterparts abroad. Correction is done when
there is an indication of inaccuracy of information or documents submitted by
WPDN Indonesia and their partners.
B.
SUGGESTION
As a country that
upholds the law, already
we should be as a citizen to obey and developing
countries rich in natural resources,
especially minerals. How, by paying taxes
and royalties as
a form of aspiration and
responsibility as citizens. Do
not just demand, process, and
take the resources that exist in nature, but do not want to develop
it. And the government also has tightened
his shoe's tax and royalty issues, because this is a sensitive issue and
concerns countries also.
REFERENCE
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