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This thesis discusses the aggressive tax planning scheme in tax avoidance by a renowned multinational company, Google tax dispute case which is currently a discussion subject in various countries including Indonesia. In view of such phenomenon, this thesis attempts to analyze the appropriate steps to be undertaken  by the Indonesian government to tax Google to obtain optimal state revenue. The analysis is conducted through the approach of Tax Treaty, BEPS Action Plan 1 is the next step in handling the digital economic tax challenges presented based on its development, and the comparison of other countries that have established policies to tax Google. The research method is qualitative with data collection method in the form of literature study and field study by conducting in-depth interviews with a key informant with understanding on the subject matter of this research. Research results indicate that new tax policies are required to overcome tax avoidance conducted by Google that is outside the scope of income tax, such as Diverted Profits Tax (DPT) in the UK and Australia and Equalization Levy in India.