Jakarta, ThedailyID — A doctoral dissertation has renewed calls for Indonesia to establish a dedicated Transfer Pricing Bill amid growing concerns over legal certainty in international taxation (May 6, 2026). The study argues that inconsistent implementation of transfer pricing regulations still triggers tax disputes and creates loopholes for cross-border tax avoidance.
The dissertation, titled “Rekonstruksi Hukum Transfer Pricing Berbasis Kepastian Hukum untuk Mendukung Optimalisasi Penerimaan Negara Indonesia,” proposes a Transfer Pricing Bill as a lex specialis framework. The proposed law aims to strengthen legal certainty and improve consistency between regulations and tax administration practices.
In particular, the framework would reinforce the arm’s length principle and clarify evidentiary procedures. It would also strengthen dispute resolution systems such as Advance Pricing Agreements (APA) and Mutual Agreement Procedures (MAP). As a result, the study believes the bill could improve taxpayer compliance and protect Indonesia’s tax base.
The issue comes as Indonesia records stronger tax revenue growth. According to Finance Ministry data, state revenue reached Rp574.9 trillion by the end of March 2026. The figure marked a 10.5% year-on-year increase. Meanwhile, tax revenue rose 20.7% to Rp394.8 trillion.
Purbaya Yudhi Sadewa said tax system improvements, including CoreTax implementation, would remain important for boosting state revenue. “Taxes continue to improve and will work even better moving forward,” he said during the APBN KiTa press conference on Tuesday (May 5, 2026).
Ikhwan Ashadi, who authored the dissertation, stressed that legal certainty remains essential in transfer pricing enforcement. He warned that inconsistent technical standards could reduce taxpayer trust and increase disputes.
In addition, the dissertation proposes a three-to-five-year implementation roadmap. The plan includes strengthening the Directorate General of Taxes and improving tax data infrastructure. It also encourages broader integration of digital taxation systems.
Overall, the study aims to support a fairer and more transparent taxation system in Indonesia. The proposed Transfer Pricing Bill is also expected to strengthen long-term state revenue protection.
