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Abstrak :
In order to anticipate fluctuative of rupiah currency over foreign currency that cause of instability between revenue with cost so government issue the policy of revaluation of fixed assets in which the policy is the option for the company. The writer is interested to analyst factors that influence company's interest to implement revaluation of company fixed assets (Cases Study at Foreign Investment Tax Service Office Two). Fixed asset is noted as amount as its acceptance price (historical cost). Revaluation of fixed asset is activity to reevaluate an asset in order the attached value in financial statement can represent the appropriate value with value when the fixed asset is reevaluated. Over the more value difference of revaluation of fixed asset is object of income tax. Type analysis of this paper is descriptive analyst, and data is collected through interview -with the officers of the Directorate General of Tax, Tax Consultants, Taxpayers that are registered with Foreign Investment Tax Service Office Two. Obtaining of seconder data is implemented on the library, laws regulation of tax, etc. The study result shows that there are some positive and negative factors that influences company's interest to reevaluate its fixed assets, one of positive faders is using loss compensation, increasing financial statement performance, lessen firm income tax, there is projection of profit and lost, give share bonus without deposit the capital and company's plan to do merger, consolidate and expand of the business. Meanwhile the negative factors is the existence of Final Income Tax amount of 10%, there is an additional sanction of Final Income Tax over assets that have not taken over before its usage period is finish and because of existence of tax administration. Revaluation of fixed assets that implemented by Taxpayers at Foreign Investment Tax Service Office Two have given optimal result for company. It is needed the further regulation on Chapter 18 article (1) of the existing Law of income Tax and there is revision over Chapter 4 article (1) letter g numeric 5 and adjusted with Chapter 4 article (1) letter g numeric 3. Decreasing tariff of Final Income Tax over the more value differences of revaluation to attract company's interest to implement its fixed assets revaluation.

Abstrak :
Price of world oil in the international market which progressively uncertained and tended to be declined on the beginning of year 1980's was quite groused the jolt of state's revenue from both oil and gas sector which became its mainstay within the government implementation funding at the time. Realizing this uncertainly global condition, the government immediately makes the orientation changer of state income source from both oil and gas sector to non-both oil and gas sector especially tax. As the real step on such orientation change, the government begins to implement the improvement of national taxation system covering the institutional and regulation system through taxation reformation of 1983. As a consequence of state income's orientation change, the duly of taxes general directorate longer the year become greater the heavy as the state income compiler. However, such thing is not become obstacle for Directorate General of Taxes. Such as we knew that there were some methods of PPN's collection, namely: 1. Addition Method, it is Calculate the value adding by calculate it on purchase price of both product and service. 2. Subtraction Method, it is calculate the value-increase 1 value-adding by reduce the purchase price of both product and service towards the sale price of both product and service wherein its component come from them purchased. Indonesia uses the Indirect Subtraction method or can also called as invoice method, within calculate the Value Adding Tax. This thing can be apparent wherein on each link of production and distribution are imposed by PPN, invoice of tax as a proof of tax collection made by taxable entrepreneur who carry out neither the taxable goods giving nor the taxable service giving or proof of tax levied becauseimport of taxable goods by Directorate General of Customs and Excise. Within the Indirect Subtraction method, can be found the taxes crediting mechanism, and within the constitution or law of PPN we have recognized the input tax and output tax as the main component in this method. Input tax in period can be credited with output tax on the same time period, if the output tax is bigger than the input tax, thus, on its difference constitutes valve Adding Tax that must paid by taxable entrepreneur. However, in condition wherein the output tax is smaller than the input tax, thus, on its difference constitutes tax's surplus that can be re-demanded or be compensated to the next tax-time. Such tax's surplus can be re-demanded or we have recognized it with called as Restitution. Giving's process of that tax's surplus is preceded with examination by Directorate General of Taxes. Process of PPN restitution's giving constitute one of DJP's service form to the tax obligatory that always obtain attention from various circles, therefore, that service improvement always continuously developed by DJP without interruption. Such thing is proposed to extend the best service to the tax obligatory especially service of PPN restitution's giving. However, which always to be obstacle within examination process in the frame of restitution's giving is request for confirmation answer of input tax which take a long time. Such thing exceedingly inflicted a loss upon the tax obligatory as on tax's surplus to be demanded restitution constitutes endured fund on government treasury within the examination process often happened wherein output tax is invisible within taxation information system because it is not yet recorded by relevant KPP, so that such process continued with clarification request which take time about one more month. Therefore, writer attempts the acceleration of restitution's giving with matching system. This system had ever been tried out on 1997, but it was mulled to be used by Taxes General Directorate with reason that administrative matters of tax obligatory have not ready yet. Besides that, such system was cancelled with reason that it requires many enclosures and this thing exceedingly burdening the tax obligatory because the high cost. In fact, however, such system has a superiority because the SPT's enclosure PPN's period besides it received by KPP wherein seller was registered, it also received by KPP wherein buyer was registered. Therefore, the confirmation can be done accelerately. Writer here views that recording process of SPT's enclosure PPN's period is too many using the human power, thereby, it cannot be avoided the occurrence of humanly mistakes of recording. Therefore if the Directorate General of Taxes issued the rules and provision which regulate that each of/all PKP obligate to enter SPT PPN's period into electronics media form, thus, confirmation process could be done quickly.

Abstrak :
Penelitian ini membahas mengenai analisis formulasi kebijakan pajak pengecualian pengenaan pajak penghasilan atas dividen luar negeri yang diterima oleh wajib pajak orang pribadi. Pengecualian pengenaan pajak penghasilan atas dividen luar negeri bagi wajib pajak orang pribadi yang terjadi akibat pengesahan Undang-Undang Nomor 11 Tahun 2020 mengindikasikan terjadinya pergeseran sistem pajak Indonesia yang semula menganut sistem pajak worldwide menjadi sistem pajak semi teritorial. Pengeleminasian pajak penghasilan atas dividen merupakan salah satu kebijakan yang cukup krusial mengingat proporsi penerimaan pajak Indonesia masih mengandalkan dari sektor pajak penghasilan. Penelitian ini merupakan penelitian kualitatif bersifat deskriptif. Kebijakan ini belum sepenuhnya melalui tahapan proses formulasi kebijakan akibat tidak ditemukannya alternatif kebijakan masalah. Kebijakan pengecualian dividen dari luar negeri yang diterima oleh wajib pajak pribadi dilatarbelakangi oleh kondisi laju pertumbuhan perekonomian Indonesia bergerak lamban yang disebabkan oleh daya saing Indonesia yang dinilai rendah, terjadinya perlambatan pertumbuhan ekonomi secara global, kurang meratanya pertumbuhan ekonomi antar daerah di Indonesia, kurang optimalnya kapasitas produksi nasional yang disebabkan oleh kurang berkembangnya industri manufaktur, permasalahan efektifitas reformasi birokrasi serta tata kelola data yang dinilai masih kurang baik, sehingga menghambat kemudahan dalam berusaha (ease of doing business). ......This study discusses to analyze the formulation tax policy of exemption from the imposition of income tax on foreign dividends received by individual taxpayers. The exemption of income tax on foreign dividends for individual taxpayers that occurred as a result of the ratification of Undang-Undang Nomor 11 Tahun 2020 indicates a shift in the Indonesian tax system which originally adhered to the worldwide tax system to a semi-territorial tax system. Elimination of income tax on dividends is one of the most crucial policies considering the proportion of Indonesia's tax revenue still relies on the income tax sector. This research is a descriptive qualitative research. This policy has not yet fully gone through the stages of the policy formulation process due to the absence of alternative policy problems. The policy of exemption from foreign dividends received by private taxpayers is motivated by the condition of Indonesia’s slow pace of economic growth due to Indonesia’s low competitiveness, global economic slowdown, uneven economic growth among regions in Indonesia, less than optimal capacity. National production caused by the lack of development of the manufacturing industry, problems in the effectiveness of bureaucratic reform and data management which are considered to be still not good, thus hampering the ease of doing business. However, this policy still needs to be reviewed considering the self-assessment system adopted by the Indonesian tax system and improvements in the administration side in terms of supporting regulations regarding investment provisions made outside of financial institutions to avoid tax evasion loopholes and tax disputes.

Abstrak :
The background of the thesis is the highly development of various financial innovations and manipulations as well as the development of international trading, which will beneficial for big companies or multinational companies. One of them is Structured Trade Finance (STF) transaction that using LFC as financing mechanism, which is conducted by big agribusiness companies. As long as the business transaction of STF produces income in Indonesia, of course it should be governed by the Indonesia income tax system. Innovation in this practical commodity business is an interesting phenomenon to determine the character of its tax. The characterization of income is an important matter that emerges in imposing the tax of STP transactions that using L/C as an instrument. It becomes an important matter because it is related to the tax treatment including determination of tax rate for the income resulted from the STF transactions. Other thing that is mattered is that the STP transactions that are conducted by Taxpayer are not transparent and not disclosed well, which indicates an avoidance effort of tax payment.

The research method of the thesis is qualitative methodology with analytical descriptive approach. The two data collection?s methods that are used in this research are study literature and field data collection techniques. The technique of study literature in data collection was conducted by reading and understanding sciences books, magazines, papers, articles, international convention and the tax regulations. Meanwhile, the technique of field data collection was conducted by observing and direct communicating with the related research?s objects.

Basically, the STF transaction is a structured finance transaction based on borrowing. The experts in STF transaction in commodity's sector are able to design structurally the financing mechanism of L/C, by doing so, group of companies which are spread in various countries will able to take advantage in their internal cash flow to create benefit through financial arbitrage opportunities in the region. The concrete advantage for the Taxpayer for the STF transaction is in form of L/C prepayment discount, which is given by the bank as an issuer of the L/C that is positioned in this country. Based on the SHS concept of income, the benefit/ income obtained by the Taxpayer in conducting STF transaction is an income that subjected to tax because there is a substance economic increase. The characteristics of income will highly detemtine whether the income will be subjected to taxes or not, and also will determine the tax treatment of those income and the tax rate that will be imposed.

The determination factor of income characteristic from the STF transaction can be based on the substance of the transactions related with the obtained income. Through this research, it is shown that the income obtained from the STF transaction by using L/C technique can not exactly be classified as a business income as well as other income, although there are several criteria of business income and interest income are fulfilled by this transaction. The L/C prepayment discount can be classified as an interest income. The main reason is that based on the substance of income, the L/C prepayment discount could be the same as an interest. The difference is only about time of payment.

The planning of STF transaction that is conducted by PT ?X? can be classified as the tax evasion, the reasons are because the Taxpayer is considered as being not transparent and dishonest, and also morally disobedience of law. Due to the more sophisticated business method and technique, Taxpayers can avoid taxes payment, not only by using loopholes or taking advantages in the weaknesses of Tax Regulations but also the weaknesses in other regulations such as banking regulations.

In determine the characteristic of income of a business transaction, which is always developed in a various ways, it is better for the Taxpayers and the Tax Authority to analyze the nature of a transaction first, so it can be acknowledged the substance of the income that appropriate with the Tax Regulations. This research concluded that all regulations in a country have to greatly support each other. Improving access to bank information for tax purposes has to be considered by the regulations maker because it can reduce the probability of tax evasion which disservice our country.

Abstrak :
ABSTRAK
Kapal asing menjadi salah satu pilihan untuk mengangkut barang. Dalam hal ini, Indonesia memiliki potensi pemajakan atas jasa pelayaran luar negeri sebagai sumber penerimaan negara. Namun demikian, seringkali terjadi perbedaan interpretasi dalam penggunaan dasar hukum pemajakannya antara WP dan DJP. Skripsi ini bertujuan untuk menganalisis substansi penghasilan yang diterima oleh K, Ltd perusahaan pelayaran luar negeri dan perlakuan perpajakan yang tepat atas penghasilan tersebut. Penelitian ini menggunakan pendekatan kualitatif dengan studi kepustakaan dan wawancara mendalam sebagai teknik pengumpulan data. Substansi penghasilan yang diterima oleh K, Ltd merupakan imbalan dari jasa pelayaran di jalur internasional sehingga perlakuan pemajakan yang tepat merujuk kepada pasal 8 tentang shipping and air transport P3B Indonesia-Singapura. Selain itu, BUT yang timbul di kasus ini yaitu BUT jasa. Oleh sebab itu, diperlukan penegasan mengenai jenis BUT yang dapat terbentuk dari perusahaan pelayaran luar negeri dalam UU PPh dan pembenahan internal Mahkamah Agung dalam menentukan Majelis yang akan memutus suatu sengketa.

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ABSTRACT
Foreign ships become one option to transport goods. In this case, Indonesia may tax income from International Traffic 39 s shipping as a source of state revenue. Nevertheless, there are some different interpretations in the use of the legal basis of taxation between taxpayers and Directorate General of Taxation. This thesis aims to analyze substance of income received by K, Ltd foreign shipping company and suitability of imposing tax on it. This research was using qualitative approach with literature review and in depth interview as data collection technique. Substance of Income received by K, Ltd is service fee in International Traffic 39 s shipping, so the impose should refer to Article 8 Tax Treaty Indonesia and Singapore about Shipping and Air Transport. Then, PE establishes in this case is Service PE. Hence it shows the necessities of clear PE definition that establish from foreign shipping company in Income Tax Law and Supreme Court Internal 39 s imporovement in assigning Judge to decide a dispute.