Implementation of Multilateral Instruments (BEPS Action 15) in Indonesia
It has come to the attention of governments around the world that aggressive tax planning practices of MNEs has shifted income to non-tax or very low tax jurisdictions. In light of this, the BEPS action plan has been introduced to tackle such issues.
One of the BEPS action plans is to implement tax treaty related measures to address certain hybrid mismatch arrangements; prevent treaty abuse; artificial avoidance of permanent establishment status; and to improve dispute resolution. However, the modification of each tax treaty amongst countries will be a matter of extensive time consumption, which would defeat the urgent need for the implementation of such measures.
