This study discusses interest payments on loan transactions between Company X and its subsidiaries based on transfer pricing rules and Government Regulation No. 94 of 2010. The purpose of this study is to determine the implementation of transfer pricing and to analyze the tax savings on interest payment transactions between Company X and its subsidiaries. This research uses qualitative research approach and data used are data from Company X and subsidiary, interview with related parties, and literature study. The result of the research concludes that interest-free loan transactions between Company X and its subsidiaries are not in accordance with the prevailing transfer pricing regulation in Indonesia and Government Regulation Number 94 Year 2010 and the interest-free loan transaction does not trigger tax savings but make Company X suffer losses by mistake companies in tax planning.

Keywords: Transfer Pricing; Interest; Tax; Implementation