A COMPARATIVE ANALYSIS OF CORPORATE TAX GROUP REGIME IN AUSTRALIA, GERMANY, AND INDONESIA
The main difference of corporate group regimes in Australia, Germany, and Indonesia is the treatment of a corporate group as a single entity or separate entities. This particular regime primarily impacts tax treatment on intra-group loss transfer and intra-group asset transfer. This paper compared the implementation of corporate group regime in these countries and analysed the effectiveness of its regime based on the satisfaction of neutrality, simplicity, competitiveness, and fairness principles. The results of the analysis concluded that there are strengths and weaknesses in each tax regime. Key improvements to the Indonesian corporate tax regime are proposed which include implementing a consolidation system. The main features of this system facilitate intra-group loss transfer and intra-group asset transfer. These recommendations are expected to increase neutrality, simplicity, and fairness in Indonesia’s tax system and potentially support corporate groups to be more competitive.