This research discusses the transfer pricing audit performance of Directorate General of Taxes (DGT) based on the tax court stipulation during fiscal year 2015-2019. This research employed qualitative research method. The data were collected through literature review and interview. The findings showed that the cases brought to the tax court solely due to administrative and technical matters had been quite significant in number, which were more than 40% of the cases settled. Unfortunately, inappropriate assessment process took the larger proportion in the failure in complying with the technical and administrative rules while conducting the audits. On the other hand, in regards with non-technical and administrative issues, DGT mostly won the cases. It means that DGT were more reliable in auditing once it complied with the technical and administrative matters. The research also showed that DGT fully realized that the infrastructure of transfer pricing handling needed supports from various aspects.

This article examines the challenges on taxing digital economic performed by Indonesian government through online marketplaces engaged as the withholder of the merchants selling their products through their platform on gross basis. Online marketplace, seen as potential sector contributing to the state revenue. The research show that tax imposition on the merchant through marketplace has raised debates, since the merchant which mostly start-up and micro-business should not be taxed like established business. Small and micro-scale business registered on an online marketplace will potentially change their marketing mode to avoid tax to get higher return on the mode could be detected by government, such as social media. Further, the online marketplace has to do another risky responsibilities beside their core business; withhold the tax and remit it to the government following the prevailing law. The heat debate on the publish lead the government to postpone the policy engaging online marketplace as withholder. As the final solution, the government imposes small percentage final tax for the business who has the turn over classified as SMEs.

This article is intended to examine the challenges of taxing digital economy due to rapid development of technology in Indonesia. Those changes should be responded equally from the government perspective pertaining to the changes in tax regulation, structure/institutional of tax organization, human resources who understand the pattern and development of digital business and have capability to formulate tax regulation suitable for the business pattern, and information technology reliable in transforming the business of the tax organization. This study occupies constructivism paradigm and qualitiative research method. The data was gathered through literature review, documentation study and interview with informant. The research showed that for all of those aspects, the Indonesian government has realized that the change is very crucial. The government of Indonesia also fully realizes that the rapid development of the economic activities and should respond it by publishing various proper regulations and initiatives. However, some of the regulations are still insufficient to respond to the existing challenges. This indicates that in reality, the government is still unable to respond to the current dynamic properly and proportionally. Organization changing on the context of bureaucracy reform also still on the progress, similarly on the development of human resources capacity and the use of technology to optimize tax collection effort. Therefore, more comprehensive improvement through engagement of various agents to properly respond to the current economic development is essentially required.

This article is a critical review and as a means of lesson learned for Indonesia taxation system based on the taxation reform undertaken by Norwegian government as a member of welfare state and OECD, that is considered as a country with high tax ratio. It is also a state which has succeed to realize welfare and income distribution without distort domestic economic stabilization. In this article, it is discussed how the Norwegian government fully aware of the role of tax reform as a mandatory task to reach the state objective by optimizing taxation as instrument of social welfare, productivity improvement and stimulus to realize friendly investment environment. Several tax reform agendas such as reduction of corporate income tax, prevention on profit shifting and until the optimization of the use of big data to support the tax reform. Indonesia on its tax reform agenda which has been commenced in 1983 has transformed significantly for many aspects such as administrative affairs and the way the government to implement the tax policy. These measures have aligned with global tax trend. However, several works remain such less optimize tax ratio during the last one decade.Keywords: tax reform, taxation system, tax administration, tax compliance, tax policy ABSTRAKArtikel ini merupakan critical review sekaligus sebagai sarana pembelajaran bagi sistem perpajakan di Indonesia atas reformasi sistem perpajakan yang dilakukan oleh pemerintah Norwegia sebagai salah satu dari kelompok negara welfare state yang oleh OECD dinilai berhasil memiliki tax ratio yang cukup tinggi sekaligus mampu menciptakan pemerataan penghasilan tanpa mendistorsi kegiatan ekonomi domestik.  Dalam artikel ini diuraikan bagaimana pemerintah Norwegia memahami sepenuhnya bahwa reformasi pajak merupakan suatu keniscayaan untuk mencapai tujuan negara yaitu menggunakan instrumen pajak sebagai instrumen pemerataan sosial, peningkatan produktivitas dan stimulus untuk mewujudkan lingkungan ekonomi yang ramah terhadap investasi. Beberapa agenda reformasi yang diulas seperti kebijakan penurunan tarif pajak penghasilan korporasi, pencegahan terjadinya profit shifting hingga pengoptimalan penggunaan teknologi dan big data dalam sistem perpajakan. Indonesia dalam perjalanan reformasi perpajakan sejak 1983 telah mengalami perubahan yang cukup signifikan baik dalam hal administrasi dan implementasi kebijakan pajak sesuai dengan tren reformasi perpajakan global. Namun, catatan penting dalam perjalanan reformasi perpajakan Indonesia adalah masih rendahnya tingkat kepatuhan dan masih rendahnya tax ratio Indonesia dalam kurun waktu satu decade terakhirKata kunci: reformasi perpajakan, sistem perpajakan, administrasi perpajakan, kepatuhan, kebijakan pajak.

The number of research evaluating the implementation of environmental tax using regulatory cost perspective is still limited. Whereas, this type of research is quite crucial in formulating tax policy to find the balance between regulatory function, revenue productivity and its impact on maintaining conducive business climate. Therefore, this research is aimed to elaborate types of environmental taxes applied in Indonesia, to map the problems arised of their implementation and their impact on regulatory compliance cost. This research occupied postpositivism paradigm with mixed method approach. The data were gathered through qualitative and quantitative technique. The result shows that eventhough Indonesia has not implement explicity a new environmental tax, there are a lot of quasi-environmental tax scatterly levied by local government and provincial government due to their authority given by the decentralization besides the corporate social responsibility performed by the business entities. Unfortunately, the reallocation budget framework on the tax/charged levied from the quasi-environmental tax has not been clear. Thus, it is essential to establish a comprehensive environmental tax with an integrated roadmap considering and accomodating the former quasi-environmental tax into a one package environmental tax policy with clear concept of earmarking with efficient collection cost.