Dinamika Perpajakan Multinasional di Indonesia: Menakar Dampak Transisi Global Minimum Tax dan Rekayasa Transaksi Afiliasi

Abstract

This study analyzes the effects of transfer pricing, thin capitalization, cross-border related party sales (CBRPS), and the Global Minimum Tax (GMT) policy on tax avoidance. The study employs a purposive sample of multinational firms in the energy, consumer cyclicals, and consumer non-cyclicals sectors listed on IDX during 2020–2025. The sample is restricted to firms with foreign affiliated entities, disclosed related-party transactions and foreign sales, and a materially debt-financed capital structure. Based on 116 unbalanced panel observations after outlier treatment, the study applies multiple linear regression to test the hypothesized relationships. The findings indicate that transfer pricing and thin capitalization significantly increase tax avoidance, suggesting that intragroup transaction structuring and interest expense utilization remain effective in reducing firms’ effective tax burdens. In contrast, cross-border related party sales significantly reduce tax avoidance, implying that greater visibility of cross-border transactions and stronger documentation requirements promote higher tax compliance. Notably, tax avoidance increases in the early phase of GMT implementation. This anomaly may be explained by the 15% minimum tax rate as a behavioral anchor, the use of the Substance-Based Income Exclusion (SBIE), which reduces the top-up tax base through exclusions for payroll costs and the carrying value of tangible assets, and transitional safe harbour provisions that provide multinational firms with room to adjust their tax strategies opportunistically before the GMT regime becomes fully established and stable. Practically, these findings suggest that the effectiveness of GMT is strongly shaped by the implementation stage and firms’ capacity to respond to regulatory change.