„In any event, the mutual agreement procedure is clearly a special procedure outside of national law… The tax treatment by P3B partners of tax authorities that do not comply with the provisions of P3B: Why ask map? The card is basically one of the tax solutions. In addition to the opposition and appeal proceedings before the tax court. CROSS-jurisdictional tax DISPUTES can arise when two countries assert each other`s right to tax taxpayers` income. Such disputes are expected to escalate if cross-border trade and investment increase. As a result, Indonesian companies can ask the Tax Directorate to negotiate with Singapore`s tax authorities for these tax deductions. International practice does not limit the timing of POPs. And that doesn`t require choosing one. Can be done simultaneously or one after the other. That is, he could have appealed to the court and there was a decision of the judge. As it is still not satisfied, again submitted to MAP. For specific purposes, POPs can also be initiated by DJP by filing a written application with taxpayers and related authorities in P3B partner countries. If the competent authority of the partner country does not respond to the request within eight months, djp will issue a notification of revocation of the MAP application, as it cannot be followed.

In response to this question, Article 25 of the OECD model and the UN Model Convention offer mechanisms outside the legal efforts provided for by a country`s national legislation. This mechanism can only be implemented by the tax authorities of a country and by a partner country, which are bound by an agreement on double tax evasion (P3B). PoPS policy in Indonesia refers to the Finance Minister`s Regulation (PMK) No. 49/KMK.03/2019 on procedures for implementing common authorisation procedures. In the meantime, the technical processing of POPs applications and the conclusion of joint follow-up authorizations will be governed by the Director General`s regulation on the PER-16/PJ/2020 tax identification number, which came into force in August 2020. Second, the POP is a „special“ dispute resolution solution (Remedi) outside the realm of internal dispute resolution, such as objections or remedies.B. POPs are considered particularly special because they are a consultation process, not litigation. It is also highlighted in paragraph 8 of the commentary on Article 25 of the OECD model, which states that PT Maju, for example, is a subsidiary whose parent company is in Japan.