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Since 2012, the statistical data of the tax court shows the increasing number of tax dispute. The procedure of Indonesian tax dispute resolution needs more than 36 months to get legal assurance. It is important to solve the problem immediately. The model of cooperation between taxpayer and fiscal is a new trend adopted by many countries. More than two decades, the recent government has changed the tax system through cooperation and encouraged entrepreneurship. OECD has given a notion on the importance of cooperation between taxpayer and tax administration. United Kingdom and Australia, for instance, have been enhancing their relationship with the taxpayer. It has been implemented by those two countries by giving quick tax dispute resolution service through Alternative Dispute Resolution such as mediation. ADR is expected to be able to create a good relationship right after the dispute ended. Indonesia can make the transformation to cooperative paradigm. Indonesia is able to make a legal breakthrough on the tax dispute resolution using ADR. ADR has the chance to control tax dispute resolution in Indonesia through administrative effort, in form of objection. Discussion with the taxpayer, concerning the objection, is expected to provide win-win solution in reaching an agreement regarding the obligation of tax payment.

Indonesian Tax Dispute Resolution in Cooperative Paradigm Compared to United Kingdom and Australia