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                                           European MNEs,
                          Dischinger, Knoll,   between 1999-  Corporate pre-tax   - 0,5               -
                          and Riedel (2013)                 reported profit
                                           European MNEs,
                          Lohse and Riedel                  Corporate pre-tax
                          (2013)           between 1999-    reported profit  - 0,4                    -
                          B. Bawono        (developing      Corporate pre-tax   - 1,2                 -
                          Kristiaji (2015)                  reported profit
                                                                                              Thin capitalization
                                           54 countries,
                       Micro Approach  (2014)  2004         ratio                             asset’s ratio between
                                                                                              rules reduce debt-to-
                          Blouin et al
                                           between 1982-
                                                                                              Tax Authorities in
                          Davies et al
                                                                                              total corporate taxes
                                                            in France in 1999
                          (2014)           400 MNEs in      Intra-firm prices   -             France loss 3% of
                                                                             Between- 1.2
                                                                             to - 0.52
                                                                             depending on the
                          Beer and Loeprick   World MNEs using   Corporate pre-tax
                          (2014)           ORBIS database   reported profit  corporate structure      -
                                                                             complexity and
                                                                             the existence of
                                                                             intangible asset

                   of  the  profit.  It  is  reasonable,  since  advance  tax   These  studies show  positive effects of current
                   planning  could arrange a complex BEPS  scheme   law  unilateral  measures, indicating that  BEPS
                   in a way to allocate the profit of MNEs as efficient   behaviors  is reduced through anti-avoidance
                   as possible  across  countries. Incorporating  this   rules  implementation.  In  other  occasion,  OECD
                   circumstance might require more complex method   suggest that  in G20  economies,  countries  with
                   of measurements.                                 higher statutory tax rates do not necessarily have
                                                                    higher fiscal losses from profit-shifting practices if
                   4.3.3  Measuring BEPS Countermeasures with       they have solid set of anti-avoidance rules as the
                   Micro Approach
                                                                    countermeasures. 45
                      Measuring   BEPS    countermeasures    is
                                                                       OECD  emphasize  the  importance  to  take  into
                   equally important  as measuring the magnitude
                                                                    account  the level  of enforcement in assessing
                   of BEPS. A number of empirical studies are
                                                                    the effectiveness of BEPS  countermeasures. The
                   conducted to examine the effect of existing BEPS
                                                                    reason is  that  tax  authorities  may differentiate
                   countermeasures. Two main  characteristics  of
                                                                    their level  of enforcement for each regulation  to
                   current existing BEPS countermeasures we should
                                                                    balance the competitiveness of their tax system.
                   remind is that  they are unilateral  and  distinctive
                                                                    Another reason is that some tax authorities do not
                   in terms of its impact to every country. The same
                                                                    have the capacity to enforce their existing laws and
                   countermeasure could be effective for  several
                                                                    regulation to tackle profit shifting practices. 47
                   countries  and then unavailing  in some  other
                   countries.  Different  business  and  tax  landscape   5.  Currently-Feasible       Options
                   may  affect  the  level  of  influence  from  similar
                   countermeasure.                                  for     Measuring      BEPS      and     Its
                                                                    Countermeasures in Indonesia
                      Several studies  generate results showing
                   that  anti-avoidance  countermeasures  have
                                                                       Both methodology and the existence of  data
                   reduced  profit  shifting  through  transfer  pricing
                   documentation 43  and  interest  limitations.
                                                                    IMF Working Paper No. 14/12 (2014). See also, B. Bawono Kristiaji,
                                                                    “Incentives and Disincentives of Profit Shifting in Developing Countries”,
                   43. Therese Lohse, Nadine Riedel, and Christoph Spengel, “The   Master Thesis for Tilburg University (2015).
                   Increasing Importance of Transfer Pricing Regulations – A Worldwide
                   Overview”,  Oxford  Center  for Business  Taxation  Working Paper  No   45. OECD, Opcit, 110.
                   12/27 (2012).                                    46. OECD, Measuring and Monitoring BEPS: Action 11 – 2015 Final
                   44. Jennifer Blouin, Harry Huizinga, Luc Laeven, and Gaetan Nicodeme,   Report (Paris: OECD Publishing, 2015): 106.
                   “Thin  Capitalisation Rules and  Multinationals Firm Capital  Structure”,   47. Ibid.
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