Persepsi Konsultan Pajak Terhadap Efektivitas Controlled Foreign Company (CFC) Rules Dalam Mencegah Penghindaran Pajak Illegal Oleh Perusahaan Multinasional Di Indonesia (Studi Pada Kantor Konsultan Pajak Taslim & Partners, Depok)

Abstract

The low level of tax compliance in Indonesia poses a challenge to achieving national revenue targets. A major issue is illegal tax avoidance by multinational companies through the use of foreign entities or Controlled Foreign Companies (CFC) operating in low-tax jurisdictions. To address this, the Indonesian government has implemented CFC Rules as part of its anti-tax avoidance policy. However, the effectiveness of these rules remains debated, especially among tax practitioners. This study aims to analyze tax consultants’ perceptions regarding the effectiveness of CFC Rules in preventing illegal tax avoidance by multinational corporations in Indonesia, and to identify factors influencing these perceptions from regulatory, technical implementation, and taxpayer compliance perspectives. Using a qualitative method, in-depth interviews were conducted with tax consultants experienced in handling multinational clients. The data were analyzed descriptively, focusing on the informants’ understanding, professional experience, and critical views of the CFC Rules. The results indicate that conceptually, the CFC Rules have strong potential to strengthen the national tax system and prevent profit shifting abroad. However, implementation faces challenges such as regulatory complexity, difficulties in obtaining data from foreign entities, and loopholes in tax planning. Tax consultants play a vital role in bridging understanding between tax authorities and taxpayers, ensuring tax planning strategies comply with existing regulations.