The Role of Tax Extension Officers in Optimizing Tax Compliance with Representative Offices

S. Wahyudi
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Abstract

The debate over the taxation aspect of the Foreign Trade Representative Office (KPDA), especially PPh Article 15, seems to be protracted and will never be finished. Meanwhile, according to the PPh and P3B Laws, KPDAs have fulfilled subjective requirements when they have or occupy an office address where the term establishment still includes a place of management.It is common for a KPDA to carry out marketing activities in the form of product promotion which is carried out continuously for the benefit of the Head Office which is proven to be able to increase and earn export earnings to Indonesia, so that the income is subject to tax in other countries or source countries (Indonesia). only as big as the share of profit that is considered to come from KPDA.The term activities that are purely auxiliary in nature which are additional activities to facilitate essential and significant activities is often the root of the problem so that the KPDA has the right not to pay Article 15 PPh.This study aims to see how the Income Tax Law and P3B regulate income from KPDA, especially business activities that are "only". Isn't it clear that supporting activities are only carrying out indoor activities, namely activities that are not related to other parties or outside parties, so that it can be said that they do not carry out business communications with other parties. The research concluded that the KPDA is required to make PPh payments for its activities either through corporate income tax funds or Article 15 PPh, if the KPDA has an office address as a place of management and conducts business activities with other parties
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税务推广员在优化代表处税务合规中的作用
围绕对外贸易代表部(简称公馆)的税收问题,特别是《公法法》第15条的争论似乎会持续很长时间,而且永远不会结束。同时,根据PPh法和P3B法,当kpi拥有或占用办公地址,其中“设立”一词仍包括管理场所时,已经满足了主观要求。KPDA以产品推广的形式开展营销活动是很常见的,这种营销活动是为了总部的利益而持续进行的,这被证明能够增加和赚取对印度尼西亚的出口收入,因此收入在其他国家或来源国(印度尼西亚)征税。只有被认为来自KPDA的利润份额那么大。术语活动纯粹是辅助性的,即为促进重要活动而进行的额外活动,这通常是问题的根源,因此KPDA有权不支付第15条PPh。本研究旨在了解所得税法和P3B如何调节KPDA收入,特别是“唯一”的商业活动。是不是很清楚,辅助性活动只进行室内活动,即与其他当事人或外部当事人无关的活动,所以可以说不与其他当事人进行业务沟通。调查结果显示,如果公检院有营业场所,并与其他机构进行业务活动,则公检院必须通过法人所得税基金或公检院第15条缴纳公检费
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