In this video, we will discuss the procedure of mutual agreement or M.A.P. Let`s take a look at the video statement of Mr. Astera Prima below! “In any event, the mutual agreement procedure is clearly a special procedure outside of national law… Where the main demand for MAP from a P3B partner country is the withholding or collection of income tax by taxpayers in Indonesia that is not in accordance with the provisions of the P3B, The Director of Regulation II submits in writing to the relevant subject a notice on the P3B partner country`s card application and may request a return based on the collection of sources or taxes, the content of the transaction and the requirement of the required documents through the tax office in which the subject is registered. The mutual agreement procedure, referred to as MAP, is an administrative procedure defined in the P3B to resolve the problems posed by the application of P3B, as stated in Article 1, point 11, of The Government Decree No. 74 of 2011 relating to the procedures for the enforcement of tax rights and obligations. At the beginning of December of this year, the author attempted to terminate the order of the Director General of Taxes sign PER-48 / PJ / 2010 on procedures for the implementation of procedures of mutual agreement (procedures of mutual agreement) on the basis of the authorization of multiple tax evasion. With the title of this article “Overview of the Procedure of Mutual Consent,” I hope useful. To better understand the general tax provisions for the application of multiple tax evasion licences, please read the explanatory note on the application of several tax evasion licences (p3B). The Director of the Tax Regulation II may provide additional explanations to Indonesian national taxpayers, including the request for necessary documentation and information, if the application can be processed at a later date to be consulted with the agent in partner country P3B, the Director of Tax Regulation II will send a written card application to the agent of partner country P3B. The negotiation process of two tax authorities is very useful in increasing knowledge of international tax POPs. During the objection is a tax dispute with the tax authorities by a pseudo-court. Or on appeal to the tax court. Second, the POP is a “special” dispute resolution solution (Remedi) outside the realm of internal dispute resolution, such as objections or remedies.B.
POPs are considered particularly special because they are a consultation process, not litigation. Paragraph 8 of the commentary on Article 25 of the OECD model also highlights, which provides that if the joint agreement results in an amendment to the tax payable in Indonesia, as indicated in Indonesia, to the amending letter and the decree on the reduction or cancellation of the tax letter, the Director General of the tax must correct, reduce or cancel the tax calculation letter or decree covered by the provisions in force.