BEPS ACTION PLAN 13: DEFINITION, BENEFIT, CHALLENGE, AND CHANGE

Abstract

This paper describes the implementation of BEPS Action Plan 13: Definition, Benefit, Challenge, and Change. The research was conducted using qualitative. It used secondary data from OECD. Lyotard was used to analyzing the data. The research showed that BEPS Action Plan 13 significantly increased transfer pricing taxpayer compliance worldwide. However, amendments regarding materiality, competent authority agreement, time, and manner of information exchange are required. As a result, the policy can enhance the information that is made available, good, and consistent to the tax administration. The policy maker and tax consultant can use this research to create sufficient BEPS Action Plan 13 for taxpayers based on tax jurisdiction. Each jurisdiction has unique and different tax administrations to respond to the BEPS Action Plan 13. Especially in Indonesia, those concerned about BEPS Action Plan 13 must publish meta-narratives to speak up about the suitable policy for Indonesia’s taxpayers toward BEPS Action Plan 13. Publishing meta-narrative is available by using the Lyotard perspective. This paper presents descriptive guidance in managing transfer pricing documents, especially Country-by-Country Reporting (CbCR). The result served the idea from OECD as the guidance indicator and taxpayers or other stakeholders (who are interested in the Transfer Pricing Document). So, changes are needed to balance the requirement between OECD and stakeholders whenever the regulation could be implemented in each jurisdiction.

Keywords

• transfer pricing
• cbcr
• tax jurisdiction