As companies grow in complexity and across jurisdictions, the transfer pricing challenge increases exponentially. Transfer prices are closely scrutinized by a range of stakeholders: internal management, fiscal authorities, regulators, investors, and even the public. Join KPMG and Thomson Reuters as we discuss the Coca-Cola decision and provide for an in-depth discussion of the case. PT CCI diduga mengakali pajak sehingga menimbulkan kekurangan pembayaran pajak senilai Rp 49,24 miliar. Transfer prices assign value to all elements of a company’s value chain. operations, resulting in a tax deficiency of more than 3.3 billion. We establish reserves to remove some or all of the tax benefit of any of our tax positions at the time we determine that it becomes uncertain based upon one of the following conditions: (1) the tax position is not "more likely than not" to be sustained (2) the tax position is "more likely than not" to be sustained but for a lesser amount or (3) the tax position is "more likely than not" to be sustained but not in the financial period in which the tax position was originally taken. Kali ini melibatkan salah satu perusahaan dalam kelompok Coca-Cola Company, yakni PT Coca-Cola Indonesia (CCI). The Internal Revenue Service reallocated more than 9 billion in income related to the use of intangible property from foreign affiliates that manufacture concentrate to Coca-Cola’s U.S. The Company is involved in various tax matters, some of which have an uncertain outcome. transfer pricing examination of its 1987-1995 tax years using a residual profit split agreed with the I.R.S.
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