1. CV OLAH (hereinafter referred to as "the Company") is a manufacturing company that produces vehicle spare parts from plastic materials. Based on the Tax Audit Warrant dated June 10, 2020, the Tax Office shall conduct a field inspection in the field of taxation of the Company for the 2018 tax year.After the examination is completed, the Examiner will notify the Company of the results of the examination on November 4, 2020 in the form of an Audit Result Notification Letter (SPHP). . In the SPHP, the Company was declared underpayment of Corporate Income Tax amounting to Rp. 800 million, which was caused by differences in treatment of expenses that were not deductible according to tax regulations.

The Company submitted its response to the SPHP and after the final discussion, the Company only agreed to Underpayment of Corporate Income Tax amounting to Rp. 300 million, while the Examiner remained in the original decision and issued the SKPKB on November 20, 2020. Because they did not agree with this matter, the Company submitted an objection. on February 15, 2020. As for the agreed tax shortfall, the Company paid it on February 12, 2020, amounting to Rp. 300 million.

Fiskus then issued a Decree on Objection on 2 June 2018 and stated that the objection to Underpayment of Corporate Income Tax was partially accepted, so that the Underpayment of Corporate Income Tax was Rp.600 million. Still not satisfied with this objection decision, the Company decided to file an appeal. On November 15, 2018, the Tax Court issued a Decision on Appeal with the following results: "accepted part of the appeal submitted so that the underpayment of Corporate Income Tax becomes Rp 350 million".

Question:

a. When can the Company submit an objection at the latest? Is the Company's decision to pay only Rp. 300 million before filing an objection and not to pay the tax payable before filing an appeal can be allowed? If it is not allowed, are there any sanctions imposed in this regard? Explain along with the legal basis!

b. If it is assumed that PT Adidaya Plastik accepts the objection decision, how much tax will still have to be paid (including tax sanctions, if any) by the Company? When should the company pay for it? Provide an explanation (and calculation) along with the legal basis!

c. When can the Company file an appeal at the latest? What are the conditions that must be met by the Company for filing such an appeal? Explain along with the legal basis!

d. Based on the results of the appeal decision, how much tax is accrued (including tax penalties, if any) by the Company? When should the company pay for it? Provide an explanation (and calculation) along with the legal basis!

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