RELATED PARTY CONCEPT, TRANSFER PRICING CORRECTION DISPUTES, MUTUAL AGREEMENT PROCEDURE (MAP) SUBMISSION: INDONESIA CASE

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