CHAPTER I
INTRODUCTION
A.
BACKGROUND
The
world is now a single
market. Raw materials, labor and
technical skills come
from all over the world. Similarly,
markets for products
and services are
now also transnational. This is because the business environment
is changing rapidly,
both domestically and globally. This change requires rapid
movement of business people to
immediately undertake a process of adaptation or adjustment to follow
the motion of the pace of change
is changing business environment so as not to
miss and can develop into much more than
the original.
In the
world of mining, of PT Adaro Energy is very familiar. Because the company is
already well known as a producer of thermal coal in Indonesia is second, single
coal miner in Indonesia, and one of the world's premier supplier of thermal
coal to market global seaborne. But in 2008, PT Adaro Energy is related to a
problem that cost the state by dragging and transfer pricing. In the practice
of transfer pricing, PT Adaro sells its coal to its affiliated companies,
Coaltrade Services International Pte. Ltd is located in Singapore and in person
it is very detrimental to the country because of the sales practices of PT
Adaro has manipulated tax evasion and royalties to the state with a transaction
that is not fair (not according to the price of coal on the market).
Transfer
pricing practices were
once only done by the company
solely to assess
the performance of the divisions
among the members or firm, but along with
the times of transfer pricing practices
are also often used
for tax management is an attempt to minimize the amount
of tax to be paid.
Transfer
pricing is done
by PT Adaro
Energy tough revealed.
Because at that time, Indonesia does not have
a standard price of coal sold
commonly used. The
absence of standard prices
make it difficult to determine whether the rates imposed
under the standard or not. In this case, PT. Adaro Indonesia (Adaro
Energy PT) suspected
of selling coal at below market
prices to affiliated companies
in Singapore in
2005 and 2006. But then sold again in the market according
to the market price.
This is intended to avoid the royalties paid to the state.
Adaro
issue has been a
concern that the prodding of
House of Representatives Commission
VII Department of Energy and Natural
Resources (EMR) to investigate the case.
B.
PROBLEM
FORMULATION
1. What
is the result of transfer pricing by PT
Adaro Energy to
the state?
2. What
causes the transfer pricing by PT Adaro
Energy's difficult to prove?
3. What
sanctions should be imposed on the irregularities
committed by PT Adaro Energy?
4. How is the government's efforts to prevent transfer pricing cases going
back?
C.
OBJECTIVE
OF THE WRITING
1. To
know the result of
transfer pricing by PT Adaro Energy to the state.
2. To
determine the cause of transfer pricing by PT
Adao Energy is
hard to prove.
3. To
determine which sanctions
should be imposed on the irregularities committed by PT Adaro Energy.
4. To
know the government's efforts to prevent transfer pricing cases occurred again.
CHAPTER II
DISCUSSION
A.
PARTINENT
IDEAS
1.
Corporation
(PT)
PT is a statutory body established under the agreement that do business with
the entire tertetu
capital divided into shares and meet the requirements set forth in the statute and its implementing regulations.
Legal basis for the establishment of
PT, are as follows:
a. Close
PT, by Act 1
of 1995 on Limited Liability Companies.
b. Open
PT, under Law No.1/1995 and Law No. 8 of 1995
on Capital Market.
c. PT
domestic investment, by Act 6 of 1968 in conjunction with Law 12 of 1970 on Domestic Investment.
d. PT
PMA, based on Law
No. 1 of 1967 in conjunction with
Law No.11 of 1970 concerning
Foreign Investment.
e. PT
(Persero), under Law No.9/1969 on Establishment
of State and Government Regulation
12 of 1998 on the
Company.
Classification of
PT visits from
holding stock mutual
relations, are as follows:
a. Holding
Company is a company that has one or more
other companies, and control through voting rights on the basis of the
percentage of shares in each company concerned; generally, the parent company
has its own business; however, if the parent company does not have a separate
business, parent company as it is a group company (holding company) is also
called the parent company.
b. Subsidiary
) is a company controlled by another company (called
the parent company).
c. Affiliated
Company is a company which is effectively controlled
by another company, or affiliated with the
company or some other company because of interest or ownership
or the same board.
2.
Definition
of Transfer Pricing
Organization for
Economic Co-operation and Development (OECD) defines transfer pricing as the price specified in the
transactions between group members in a multinational company in which a
specified transfer price can deviate from the fair market price for his group
throughout the match. They can deviate from the fair market price for their
position within the state is free to adopt any appropriate principles for
corporate.
Simamora
in Yeni Mangonting
(2000: 70), transfer
pricing is defined as a special selling price
used in the exchange of inter-divisional division recorded revenues for the
seller (selling division) and the division of costs
buyers (buying divison).
Transfer pricing is often also referred to as intracompany
pricing, intercorporate pricing, interdivisional or internal pricing are prices
calculated for the purposes of management control over the transfer of goods
and services among members (group of companies). Transfer pricing is usually
set for products between (intermediate product) which is the goods and services
supplied by okeh division seller to buyer.
When
examined it further, transfer pricing can deviate significantly
from the agreed price. Therefore
transfer pricing is also often associated with a
systematically engineered prices that are aimed
at reducing the profits will reduce the amount
of taxes or duties of a country.
3.
Goals
of Transfer Pricing
Simamora
in Yeni Mangonting
(2000: 71) states
that the purpose of transfer pricing is to transmit financial data among departments or
divisions, the company filled in each time they use the
goods and services with each other.
Besided
that goals, Ronen and McKinney in Yeni Mangonting (2000:
71) also states
that transfer pricing is
sometimes used to evaluate the performance of the division and the division
managers motivate sellers and buyers
to the division decisions
are compatible with the overall corporate goals. A transfer pricing system should satisfy
three objectives: acurate performance evaluation, goal congruence, and
preservation of divisional autonom.[1]
While
Hansen and Mowen
in Yeni Mangonting
(2000: 71) states
that within the scope of multinational
companies, transfer pricing is
used to, minimize the taxes
and duties that
they incur throughout the world.[2]
4.
Methods
of Transfer Pricing
Several
transfer pricing methods are often used by corporations and conglomerates
divisionalisasi / departmentation is:[3]
a. Cost-Based Transfer Pricing.
Companies
that use the transfer
method to the cost of setting the transfer
price variable and
fixed costs that
can be in 3 forms,
is : full cost, full cost plus markup and variable cost plus fixed fee.
b. Market Basis Transfer Pricing.
If there is a perfect market,
transfer pricing method based on the market price of these is the most appropriate
measure because it is independent. However, the limited market information that
is sometimes an obstacle in the use of transfer pricing is based on market
prices.
c. Negotiated Transfer Prices.
d.
In
the absence of prices, some companies allow the divisions within the company
with an interest in transfer pricing to negotiate a transfer price desired.
Negosiasian transfer price reflects kontrolabilitas perspective inherent in the
centers of responsibility for each division are concerned that in the end that
will be responsible for a negotiated transfer price.
5.
Transfer
Pricing in Multinational Companies
There
are two objectives/goals to be achieved transfer pricing by multinational companies is:[4]
a. Performance Evaluation.
One of the ways
used by many companies
in assessing what level of performance is to
calculate its ROI or Return On Investment.
Sometimes the level of ROI for a division
with other divisions
within the same
company are different from one another.
For example, division sellers want a
high transfer price which will increase income, which will automatically
increase their ROI, but on the other hand, the division buyers demanding a low
transfer price which will result in an increase in income, which means also an
increase in ROI. This sort of thing is what sometimes makes transfer pricing
that is wedged position. Therefore, to overcome this problem, the parent
company would be very interested in transfer pricing.
b. Optimal Determination of Taxes
Tax
rates between one
country to another different.
This difference is caused by the economic, social, political,
and cultural force in the country. Africa
for example, due to the low level of investment,
the applicable tax rate in the country is low. But
if we are talking about America, it is unlikely that the tax rate applicable
in the country are the same as in the African country.
It is clear, as
in developed countries like America
very high level
of investment, as evidenced by
the growth rate of the enterprise is increasing. On this basis the tax
rate is set high in the country concerned.
6.
Transfer
Pricing in Indonesia
The
transfer pricing practices could result in a transfer of income or tax base
and / or the cost of a taxpayer to another
taxpayer, which can
be engineered to reduce the
overall amount of tax payable on
the taxpayer-taxpayer who has such relationship. Actually
lack Multimorbidity that could arise
because of the practice of transfer
pricing can occur between domestic taxpayers or the State Taxpayers with foreign parties, particularly those domiciled in Tax Haven Countries (countries that do not levy / tax levy is lower
than Indonesia) .
Directorate General of Taxation, through the Director General of Taxation
Circular N0. SE-04/PJ.7/1993
on March 3, 1993 states that lack Multimorbidity from
the practice of transfer pricing may occur on:
1)
the sales
price;
2)
the purchase
price;
3)
The allocation of
general and administrative costs (overhead cost);
4)
The imposition of
interest on a loan by shareholders (shareholder loan);
5)
Payment of
commissions, licenses, franchises, leases, royalties,
compensation for management services,
engineering services and return for
exchange for other services;
6)
Purchase of
property by the company's
shareholders (owners) or a related party
which is lower than
the market price;
7)
Sales to
foreign parties through
a third party that is less / have no
business substance (example dummy
company, letter box company or reinvoicing center).
The
following will be given some examples of
cases that causes less-fair arising from the
practice of transfer pricing, are
as follows:[5]
1.
Less-fair Sales
rice
PT
A has a 25%
stake in PT B. The
delivery of goods to the PT A to PT B,
PT
A imposes a selling
price of Rp. 160.00 per unit, in contrast to the
price calculated on the transfer of
the same item to PT X (no relationship)
is Rp. 200.00
per unit. In the
example above, the
market price of comparable
(comparable uncontrlled price) on the same item
is being sold to
PT X is no
special relationship. Thus a reasonable price (arm's length price) is Rp. 200.00 per unit.
Price is used
as the basis for calculating income
and / or tax.
2. Less-fair of Purchase Price
Hong Kong
H Ltd owns 25%
of PT B. PT B
importing goods produced H Ltd. at a price of
$ 3000.00 per unit.
The products were sold to PT Y (no relationship) at a price of Rp. 3500.00 per unit. In the example above,
first of all look comparable market prices
for the same item, or a similar kind
on the purchase / import of existing
parties or the special
relationship between the parties that there is no special
relationship. If the difficulties has been found,
then the selling price minus the approaches can be applied, ie by subtracting
gross profit (mark-up) plus reasonable other expenses incurred from the
taxpayer to the selling price of goods that do not have a special relationship.
If
reasonable profit obtained is Rp. 750.00 then, fiscally reasonable prices for
the purchase of goods from H Ltd. Hong Kong is Rp. 2750.00 (U.S. $ 3500.00 -
USD 750.00). The price of a basic calculation of the cost difference PT B and
Rp. 250.00 between debt payments to H Ltd Hongkong with the cost of it should
be taken into account as a disguised dividend payments.
3. Less-Fair allocation
of general
and administrative expenses (overhead cost)
Head office
of permanent overseas
in Indonesia often
allocate general and administrative
costs (overhead costs) to the BUT. Allocated costs include:
a. Trainier
expense for employers BUT in Indonesia that celebrated kantor pusat di luar
negeri;
b. Travel
expenses to the directors of the central
office of each BUT;
c. Administrative
costs / other
management from a central office running
costs of the company;
d. Costs
incurred research and development head
office..
The allocation of
these costs over the allowable benefits comparable
to each permanent and not a duplication
of costs.
4.
Less-Fair charging interest
on a
loan by
a shareholder.
H
Ltd. in Hong Kong
has a 80% stake
in PT C with a capital that has not been paid Rp
200 million. H Ltd also provide a loan
of USD 500 million with an interest rate of 25% or Rp 125 million a year. The
prevailing interest rate is 20%.
In connection with the above transactions, are required to determine
the amount owed back PT C. Loan of USD 200 million is considered as the capital of disguise, so the amount of debt
that can be
recognized PT C amounted to USD 300 million (USD 500 million
- USD 200 million).
Interest expense that
may be imposed on the borrowing
and lending transactions above
is Rp 60 million
(20% x Rp 300 million), which means there is a positive correction.
5.
Less-fair of commission
payments, licenses, franchises, leases, royalties,
compensation for management services,
engineering services and compensation
for other service fee.
PT
A computer company, to license to PT X
(no relationship) as the sole distributor
in country X
to market the computer
program by paying a 20% royalty on net sales. Additionally
PT B in country B (no special relation) as the sole distributor and
pay a royalty of 15% of net sales. Transactions above the royalty
PT B also had 20%. This is
because the computer program
that is marketed by PT B is equal to that marketed
PT X.
6.
Purchase of
property by the company's
shareholders or by
a related party at
a price lower than the market
price.
PT
A holding 50% of PT B stocks. Property company PT B form A vehicle purchased at
a price of Rp 10 million. The book value of the vehicle is USD 10 million. The
market price of similar vehicles in the same state Rp 30 million. From the
above transaction can be seen that the market price of the vehicle is
comparable to Rp 30 million, the taxable income of the positive corrected PT B
Rp 20 million (USD 30 million - USD 10 million). As for a difference in price
of USD 20 million is in the form of dividend income by PT B should cut income tax
article 23.
7.
Sales to
foreign parties through
a third party that has no business substance (letter
box company).
P PT I in Indonesia which
has a special relationship with H Ltd. in Hong Kong, two
of them is the subsidiary K in Korea. In its PT I export goods directly
delivered to the X
in the United States at the request of H Ltd.
in Hong Kong. The
cost of goods is Rp
100 and PT
in Indonesia I
always charge a
price of Rp 110. Moderate H Ltd Hongkong charge X
in the United States. The information
obtained from the United States
shows that X buys
goods at a price of Rp 175.
For
the next information to indicates that H Ltd Hongkong just a Letter Box Company (reinvoicing center)
without business substance.
Because of Hong Kong's tax rate is lower than
in Indonesia, then
there is a hint of
any attempt to divert taxpayer taxable profits from Indonesia to
Hong Kong in order to obtain n tax savings. Having regard to the function (business substance)
of H Ltd Hongkong, then intermediaries
such transactions (for tax calculation) is considered non-existent, so the selling
price in Indonesia PT I correctued by USD
65 (USD 175 - USD 110).
B.
DISCUSSION
1.
As
a result of transfer pricing by PT Adaro
Energy to the state
PT
Adaro Indonesia (PT Adaro Energy Tbk) is the second largest coal producer in
the country which has a flagship product Enviro Coal, low-calorie coal and
environmentally friendly. Companies which have coal reserves reach 928 million
tonnes with an area of 34 940 hectares of the previous mining conglomerate
Tanoto. But, due to the collateral Deutcshe Bank, the company was later bought
by a consortium of Indonesian businessmen cheap prices. The consortium, in
which Edwin Soryadjaya, Uno Uno S, Teddy Rachmat and Garibaldi Boy Thohir who
is now the Managing Director of PT Adaro Indonesia.
PT Adaro Indonesia suspected of
committing tax evasion and royalties to the state by way of transfer pricing.
Therefore, Adaro manipulation of tax evasion by buying and selling coal
unnatural (not in accordance with the international market price of coal) to
its affiliated companies Coaltrade Services International Pte. Ltd. of
Singapore.
Seven
years ago, Adaro entered into an agreement with Coaltrade Services
International Pte Ltd, a company paper (paper company) in Singapore. The
agreement states that the Adaro coal sold per year at a price and under the
prevailing price in the market. Coaltrade and sell at international prices. Who
sold not just any coal, but high-grade coal.
In 2005,
Adaro sells to companies
Coaltrade of Singapore
at U.S. $ 26 per
ton, while the market
price of U.S. $
48 per ton. Whereas in 2006, Adaro
sells to Coaltrade U.S. $ 29 per ton, while the international
price of U.S. $ 40 per ton. With 2005 sales volume
reached 26 million tons over 2006 and
reached 34 million tons, there is a difference
between the selling price and the selling price to the international Coaltrade respectively U.S. $
589.9 million (Rp 5, 8 trillion by 2005 average exchange rate of Rp9.800 / U.S. $) in 2005 and U.S. $ 363.1
million (Rp3, 3
trillion, with the
average exchange rate in 2006 Rp9.096/US
$) in 2006.
If
calculated based on market prices, total
revenue in 2005 should
amount to U.S. $
1.287 billion in 2006 and U.S. $ 1.371 billion.
Means, there is a difference Adaro sales to sales
based on market prices. If in rupiahs reached Rp
9.121 trillion. Not
to mention the potential loss
of state royalties
ranging from 13.5% the value of Rp 1,231 trillion.
As a result of
transfer pricing that occurred in 2005-2006 and
an estimated Rp 9
trillion from the
sale of the hidden. So that losses related
state taxes and royalties
estimated at Rp 4-5
trillion. Royalties are to be paid
according to the value of the
sale price. The alleged transfer
pricing that decreases the value
of sales resulting in taxes and royalties to be paid automatically also fell. In addition, transfer pricing
by PT Adaro also indirectly impacted due to the poor people who live in the mine
due to the presence
of such deviations PT Adaro also have taken
away the right of people to
obtain government should fund the
development of the share of the payment of taxes
and royalties the.
2.
Cause
of
transfer pricing by PT Adao Energy difficult to prove
Transfer
pricing by PT Adaro
was actually started
in 2007 due to sticking
battle Tanoto conglomerate
with Edwin Soeradjaya
Cs. From there comes the alleged PT Adaro
Indonesia coal sold
at below market prices to its affiliated
companies in Singapore, Coltrade PTC Services
International, Ltd. in 2005
and 2006. By Coltrade,
coal was then
sold again to the
appropriate market price of the market. This
is intended to avoid the payment
of royalties and taxes that should be
paid to the state treasury.
This case
was originally reported by the Department of Energy and the Director General of
Taxation to the Attorney General, so that this case was handled AGO (Attorney
General). But along with the investigations that have been carried out, finally
AGO itself has stopped the transfer pricing investigation PT Adaro Indonesia.
According to him, this case is already completed and there is no problem in it
and conclude that PT Adaro himself has paid all royalties and taxes that pointing.
It is very
troubling the hearts of members of the House of Representatives
Commission VII, so
they are proposed for the formation of the Special Committee to investigate the coal directly on the case, because
they considered that the Attorney General has not been incompetent in handling this case. Because
transfer pricing case that this happens,
so quaint and intricate
investigation and must be done carefully and
thoroughly.
Complexity of
these cases occur because the two
companies affiliated with cleverly doing financial
engineering by exploiting regulatory
weaknesses in Indonesia
that is still of profanity (in this case the price of standard coal in
Indonesia is still uncertain). Simply put, the model measures
the irregularities done is to utilize other
firms in the Singaporean and other countries, such as Mauritius and Virgin
Island, a favorite place for Indonesian conglomerate to commit money
laundering (money laundering).
Both
companies manipulate tax evasion by selling
coal traksaksi improperly
(does not match the price of coal on the
international market) with
argue to fluctuations in commodity prices. If referring to the available data, clearly states harmed
in this case.
Losses
due to the country's transfer pricing case is
the implication of weakness in
terms of national taxation system. Because
once I figure poorer until in 2008 the government
does not have any guidelines on transfer pricing or tax
could also indicate
avoidance.
Proof
against
manipulation
attempts
indication
that price
is indeed
very
difficult.
No
explanation of
how
and
technical
mode
is very easy,
but it's
proving
very
difficult
through
the document.
This
game
can not
be proved
if
only
examined from
ordinary
accounting
audit
mechanism
which is conducted every
year
by the company concerned.
Therefore,
in
their search
efforts
need
mechanisms
investigative
audit.
3.
Sanctions should be imposed on the irregularities
committed
by
PT
Adaro Energy
In the case of
transfer pricing
taxation
enters
this
region,
is likely to be
completed
without any
further
investigation.
Due
in mid-2008,
Directorate General
Taxation
Nasution
said,
Adaro
has been
called
and
admitted
mistakes
on tax and
royalty
companies.
Adaro
also
agreed to
pay
the tax
deficiency,
but
not
be fined
based
on
sunset policy.
In fact,
since the
beginning of
sunset policy
program
for
the removal of sanctions
for
individual taxpayers
who
voluntarily
sign up
to
obtain
TIN
in 2008.
So,
not
intended for
institutions
or bodies,
especially
in
large scale enterprise
financial
calculations
have the ability
to
pay a
tax
penalty.
It's
also
a big question
as
Adaro
floor
plans
in the capital market.
When viewed
from the
side of the law,
because
transfer pricing
tax evasion
that
has deviated
from
the applicable
tax provisions,
because
the
substance of
the state should
be able
mempajaki
multinational
companies
in
larger quantities.
Thus
do
companies
that
will be subject to
criminal sanctions
taxation,
to
Indonesia
in accordance
with
Law No.
16 of 2000
provided for in Article
39,
that a
tax
crime
would
be punishable by
imprisonment of
six (6)
years and a fine
high
4
(four)
times the
amount
of tax payable
is
not
paid or underpaid.
The difference between
tax avoidance
with
tax evasion
is very
thin
and
the business
ethics
of
the
transfer pricing practices
can
lead to
moral hazard,
because
contrary to
applicable regulations.
In addition,
the Court
per-taxation
assessed
a
comprehensive solution to
resolve
tax
cases,
including
allegations of
transfer pricing
tax-manipulation
performed
a number of companies,
also
Asian Agri
business group.
Because
the problem
of transfer pricing
has not
been
criminally
prosecuted,
because the actual
tax purposes
is not
punishing
people
but
that
money
or the
right of the state
is not manipulated.
In
the
Tax Act
article 18
paragraph
3
also
confirmed
the tax
issue
is not
included in the
criminal
realm.
4.
Government
efforts
to prevent transfer pricing cases occurred back
Transfer
pricing is certainly very detrimental to the state, so as soon as possible as
a responsible government of
the state itself must act quickly in respon
and overcome. Also
required the government's seriousness in dealing with taxes and royalties to the state,
because indirectly, if the country loses, then
the impact will also be influence
for the country's own citizens. So that, we
need the efforts of the government to transfer
pricing cases as that of PT Adaro does not
happen again. One,
the government's efforts to prevent
transfer pricing is adding DG Taxation authority
to correct the mutual agreement between the taxpayer of the Interior (WDPN) with their
counterparts abroad. Correction is
done when there is an indication of inaccuracy of information or documents
submitted by WPDN Indonesia and their partners. [6]
This
provision is contained in Article
19 of Regulation Directorate General of
Taxation Number Per-48/PJ/2010 on Procedures for Joint Implementation Agreement Procedure (Mutual Agreement
Procedure) Based on Avoidance of Double Taxation (P3B). Beleid effective from 3
November 2010.
P3B
an agreement between the Government of Indonesia with the
state government or partner jurisdictions to
prevent double taxation and
tax evasion. However, the above efforts will only prevent transfer pricing, and not necessarily to
increase tax revenue for the
state. however, it depends
on the method and
the quality of the correction itself Taxation
Office. The details, appropriate penalties for perpetrators of
transfer pricing should also keep running, because
that's where one of the tax revenue for the
state as compensation from
the embezzlement occurred.
CHAPTER III
CONCLUSION AND SUGGESTION
A.
CONCLUSION
1. Talking
about taxes and
royalties, which is normally found in each
person's mind is this is an obligation that
must be paid to the State as a form of responsibility and aspirations of
a people. However,
there are those who assume that the payment of taxes
and royalties to the state is something that is very difficult, so
there was a deviation in the form of transfer pricing cases. One of its
associated companies is PT Adaro Energy.
This case is very
detrimental state, let alone
the number has reached trillions.
In addition to the state, people who live in the
mine area was also not miss out
the case due to
the development fund.
2. Transfer
pricing cases oeh
PT Adaro is
very difficult to accomplish. Because the government did not have a standard price in the sale of
coal, so that although the mode that was
already known, but
the proof is very hard to do.
3. In
the case of transfer pricing
is, in the end Adaro
also admitted that the company had
meakukan irregularities. Adaro also agreed to
pay the tax deficiency,
but not be fined
based on sunset
policy. In fact, since the
beginning of sunset policy program for the removal
of sanctions for individual
taxpayers who voluntarily sign up to obtain
TIN in 2008. So,
not intended for institutions
or bodies, especially in large scale enterprise financial calculations have
the ability to pay a tax penalty.
4. Transfer
pricing case is a
case that is very detrimental to the
state. And if this occurs,
then increase the
country's foreign exchange deficit
will be even longer. And to prevent this,
the government has endeavored to
prevent the occurrence of this case, by adding
the Directorate General of Taxation authority to correct the
mutual agreement between the taxpayer
of the Interior (WDPN) with
their counterparts abroad. Correction
is done when there
is an indication of inaccuracy
of information or documents submitted by WPDN
Indonesia and their partners.
B.
SUGGESTION
As a country that
upholds the law, already
we should be as a citizen to obey and developing
countries rich in natural resources,
especially minerals. How, by paying taxes
and royalties as
a form of aspiration and
responsibility as citizens. Do
not just demand, process, and
take the resources that exist in nature, but do not want to develop
it. And the government also has tightened
his shoe's tax and royalty issues, because this is a sensitive issue and
concerns countries also.
REFERENCE
BIBLIOGRAPHY
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