REVIEW OF CERTAINTY ASPECT AND REVENUE PRODUCTIVITY PRINCIPLES IN THE SECONDARY TRANSFER PRICING ADJUSTMENT POLICY IN INDONESIA

Abstract

This article reviews the developments of secondary transfer pricing adjustment (STPA) regulations in Indonesia following the enactment of Law Number 7 of 2021 concerning the Harmonization of Tax Regulations and the dynamics of tax disputes surrounding the determination of STPA in the Indonesian Tax Court. This article contains a comprehensive analysis of the phenomenon of STPA policy in the practice of transfer pricing audits in Indonesia, with a particular focus on the principles of certainty and revenue productivity in taxation. Several ideas and recommendations related to improving STPA policy to provide greater certainty and support tax revenue contributions are also presented in the closing section of the article.