This study aims to determine the effect of the application of the Micro, Small and Medium Enterprises (MSME) Final PPh incentives borne by the government and the understanding of MSME taxpayers' taxation on MSME taxpayer compliance at KPP Pratama Surabaya Sukomanunggal. The research method used is a quantitative method. Sampling was based on purposive sampling method with 100 respondents. Data collection was done by using a questionnaire. The data obtained were processed using Statistical Product and Service Solutions (SPSS) 25. The results showed that the implementation of MSME Final PPh incentives was borne by the government and the understanding of MSME taxpayers' taxation had an effect on MSME taxpayer compliance.

This research aimed to determine the concept of related parties between countries as the entry point for resolving the dispute over Transfer Pricing (TP) through Mutual Agreement Procedure (MAP). This research was conducted with qualitative methods to observe the phenomena in the practices of related parties and their relation to the submission of MAP. The data employed are primary in structured interviews and content analysis sourced from research results and regulations issued by the government. The results of this study indicate that to be resolved through MAP, a Transfer Pricing correction dispute must occur between two countries that have the same interpretation of the determination of the related parties. So, not all TP correction disputes across countries can be resolved through MAP because each country has autonomous rights to define related parties differently.

Penelitian ini bertujuan untuk mengetahui apa sebenarnya permasalahan mendasar yang dihadapi dalam penyelesaian sengketa koreksi Transfer Pricing (TP) melalui MAP di Indonesia. Penelitian ini dilakukan dengan metode kualitatif dalam rangka mengamati fenomena yang terjadi pada praktik penyelesaian MAP. Data yang digunakan yaitu, data primer berupa hasil wawancara terstruktur dan data sekunder berupa data dan informasi yang diperoleh dari buku, jurnal, laporan, hasil penelitian, dan peraturan yang diterbitkan oleh pemerintah. Hasil penelitian ini menunjukkan bahwa hambatan yang terdapat di dalam penyelesaian sengketa koreksi TP melalui MAP di Indonesia secara umum terbagi atas hambatan internal yaitu hambatan yang berasal dari dalam Direktorat Jenderal Pajak (DJP) dan hambatan eksternal yaitu hambatan yang berasal dari luar DJP. Hambatan internal terdiri atas Sumber Daya Manusia (SDM), Keuangan (Budget), dan Teknologi Informasi (TI). Sedangkan hambatan eksternal terdiri atas hambatan dari negara mitra, hambatan komunikasi atau bahasa, hambatan dari Wajib Pajak (WP), dan hambatan dari regulasi.

The purpose of this study is to explore the implementation of the Final Income Tax Government-borne for SMEs incentives, socialization strategies, and obstacles during its implementation at KPP Pratama Palembang Ilir Barat. The research method used is qualitative with exploratory studies. Data collection is carried out using library and field research methods in the form of interviews. The steps taken start from data collection, data reduction, data presentation, and drawing conclusions. The results of the study indicate that presenting the Final Income Tax Government-borne for SMEs incentives at KPP Pratama Palembang Ilir Barat is in accordance with the relevant laws and regulations. In increasing the participation of taxpayers in this program, the socialization strategies carried out are holding tax webinars, conducting tax campaigns on official social media, utilizing employees to participate in campaigns, and conducting tax campaigns using print media. During the implementation of this policy, several obstacles are encountered. These obstacles include: Taxpayers' understanding of tax incentives is still low, obstacles during socialization through webinars, obstacles in reporting realization, and obstacles in the ManDOR application. The novelty of this research is examining the implementation of Regulation No. 23/2018 when tax incentives are given during the COVID-19 pandemic.

Music is a work of intellectual property and art that can become a national potential that must be protected. As technology develops, bush communities are close to music in their daily lives for entertainment, industry, commercial and education. And also makes music or songs more quickly known in the ears of listeners thereby increasing its utilization. The creator or owner of the right to use the music has the right attached to it to get compensation for the use of copyright and / or related rights or commonly known as royalties. The creator or right owner must be a member of the Collective Management Institute (LMK) to be able to obtain economic rights in the form of royalties so that only LMK, the representative of the creator or right owner, collect and distribute royalties. LMK as a non-profit entity receives income in the form of fees or commissions for the total income received from the beneficiaries. Of course, income from the use of music has been deducted by income tax article 23 and can be used as a tax credit with annual income tax payable. The question arises as to who exactly the income is attributed to and who is entitled to the tax credit, as well as how the taxation aspects of the distribution of royalties to the creator or right holder so that in an effort to support effective tax administration and on the basis of justice. Keywords:  Royalty Income Tax, Collective Management Institute, Music Utilization