IMPLEMENTASI KEBIJAKAN PMK 172/2023 TENTANG TRANSFER PRICING DOCUMENT DALAM MENINGKATKAN TRANSPARANSI PELAPORAN PAJAK DAN KEPATUHAN WAJIB PAJAK

This study aims to analyze the implementation of Minister of Finance Regulation (PMK) Number 172 of 2023 concerning transfer pricing documentation in order to improve tax reporting transparency and taxpayer compliance in Indonesia. Tax avoidance practices through unfair transfer pricing mechanisms pose a serious challenge to the national tax system. PMK 172/2023 is presented as a strategic policy to strengthen supervision and ensure that transactions between affiliated entities are conducted in accordance with the principles of fairness and business practice. The research method used is a qualitative descriptive approach with a case study approach. Data were obtained through in-depth interviews with sources directly involved in the preparation of transfer pricing documentation. The results show that this policy has encouraged improvements in the quality of reporting and taxpayer compliance, although technical and administrative obstacles remain such as document complexity, limitations of the accounting system, and gaps in understanding among business actors. Recommendations include strengthening technical outreach and education, simplifying documentation procedures, increasing human resource capacity, and periodic policy evaluations. With consistent implementation and support from the tax authorities, PMK 172/2023 is expected to create a more transparent, fair, and accountable tax system.