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However, in the process of divesting the business, PT A implemented a policy to not transfer their assets and liabilities
                  to the new companies in order to avoid tax expenses that might be incurred. The policies on the assets and liabilities
                  management in branch and main offices of PT A are as shown in Table 1. Table 1 shows that none of PT A’s recorded
                  assets was transferred to the new companies, even though the assets are used and controlled by the them to continue
                  the operations. Asset in the form of receivables were also not transferred and remained written under PT A’s accounting
                  record until the due dates. If a customer wishes to do another pawn transaction after the due date, it will then be
                  recorded in the accounting book of the new company that operates in that particular area. Prepaid outlet rent remained
                  written under PT A’s accounting book even though several outlets are used by the new companies. The same also
                  applies to the fixed assets and liabilities.

                  In terms of taxation, by the end of 2019, PT A did not record any compensable loss, and they recorded retained earnings,
                  hence the levied corporate income tax (Article 25 Income Tax) in 2020. In addition, PT A along with its new companies
                  are not taxable enterprises, meaning no Value Added Tax (VAT) credit to be claimed and imposed.

                  4.1  Company Divestiture’s Tax Implications
                  The strategy undertaken by PT A in order to comply with the scope of the business area is establishing a holding
                  company that established new companies without transferring assets and liabilities of PT A to these new companies. By
                  not transferring assets and liabilities, operationally nothing happens because all PT A’s branch offices are still under the
                  control of PT A, which causes all revenues and expenses to remain recorded at PT A. Therefore, PT A’s operating income
                  and expenses looks greater than it should be. Then, for new companies, the revenue will appear lower than it should
                  be. Although some of new companies’ operational expenses are recorded by PT A, each new company have to record
                  board of directors’ salary thus it can be expected that new companies will experience large operational expenses or
                  even cause losses for the current year.

                  Although for the majority shareholder, who records the profit and loss is not a significant issue. However, if the PT
                  branch offices’ assets and liabilities are transferred to new companies, expectedly the new companies will generate
                  profit or reduce loss for the current year. If high profit or minimal loss was generated by new companies, it would
                  increase the confidence of any unaffiliated parties to provide financing loan to new companies rather than if there is
                  no transfer of assets and liabilities. This external financing can be used for business expansion so the shareholders and
                  affiliate parties does not have to provide financing.

                  The divestiture of PT A has made their branch offices in the provinces change into independent companies, which
                  means that every new company has their own tax liabilities albeit their status in the business group. Nevertheless, PT A
                  did not transfer the assets of their branch offices to the new companies and to parent company to minimize or avoid tax
                  expenses during and after the process. In this context, taxes that are related to asset transfer are Value Added Tax (VAT)
                  and Income Tax. VAT could not be levied on PT A and its new companies because they were not taxable enterprises.
                  Ergo, the divestiture of PT A has implications on the income tax. The income tax implications on transfer of assets in PT
                  A reviewed from the group’s interest is shown in Table 2.

                                             Table 2  Tax Implications on Assets Transfer

                                                   Implications If Assets are Transferred  Implications
                             Account                                                If Assets are Not Transferred
                                               During Assets Transfer  Post Assets Transfer
                   Receivables                        No                Yes                  Yes
                   Prepaid Rent                       Yes               No                   Yes

                   Fixed Assets                       No                Yes                  Yes
                   Other Receivables                  No                Yes                  Yes
                   Other Current Liabilities          No                No                   No
                   Long-Term Loan                     No                No                   No







                                                                                 International Conference on Sustainability  11
                                                                                 (5  Sustainability Practitioner Conference)
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