Beruflich Dokumente
Kultur Dokumente
INDONESIA - NETHERLANDS
Investment in Indonesia
Source:
• http://www.bkpm.go.id/images/uploads/investasi_indonesia/file/Bahan_Paparan_TW_IV_2016.pdf
• http://www.bkpm.go.id/images/uploads/file_siaran_pers/Paparan_Indonesia_TW_IV_-_2017_Kepala.pdf
3. INDONESIA – NETHERLANDS DTC
T
E
R Keppres 92/2003
Effective from
M 1 January 2004
1991 I 2015
• Indonesia – • Protocol • Indonesia –
Netherlands • Protocol N Netherlands • Protocol
DTC A DTC
6 March 2017
14 June 2017 1 August 2017
30 July 2015 Indonesia 1 October 2017
Diplomatic Note
Protocol Signing Ratification Entry into Force Effective Date
Exchange
(Perpres 24/2017)
3. INDONESIA – NETHERLANDS DTC
Permanent • Construction, Installation, etc, 6 Months
Establishment • Furnishing of Services, 3 Months
Dividend • 10%
• 10%
• Interest paid on loan made for a period of more than 2 years or is paid in
Interest connection with the sale on credit of any industrial, commercial or scientific
equipment (Art. 11 para. 4) shall be taxable only in the resident State
Royalty • 10%
4. DTC PROTOCOL 2015 (Main Provisions)
1 •Dividend
2 •Interest
4 •Exchange of Information
New provision
Ammendment
DIVIDEND AND INTEREST
PROTOCOL
…remuneration derived by a resident of one of ...interest arising in one of the two States shall
the two States in respect of an employment be taxable only in the other State if the
exercises aboard a ship or aircraft operated in beneficial owner of the interest is a resident of
international traffic may be taxed in the State of the other State and if the interest is paid on a
which the enterprise is a resident. load made for a period of more than 2 years or
is paid in connection with the sale on credit of
any industrial, commercial or scientific
equipment,...
OTHER PROVISIONS
No
Resident of DTC
Partner
Yes
Refund
Administrative No
& Specific No Treaty
Requirement Benefit
MAP
Yes
It is not
No
Abusive & No Treaty
Beneficial Benefit
Owner
Yes
• Entity, established by law, not an income tax subject which functions are:
Transparent • pooling fund from Investor and then invest it for and in the name of Investor; and
Entity • receiving/earning income from the investment and then pass all of it to the Investor
based on each investment proportion
• Starting from 23 June 2017 (CA Agrement signed), CFMA through Investment Manager
or Custodian, for and in the name of CFMA Investor can claim DTC benefit as long as:
Main • the Investor is Netherland’s resident and the Beneficial Owner; and
Provision • each Investor satisfy the requirement & the procedure in Indonesian law and its
implementing regulation regarding DTC implementation
• Investor who invest through CFMA can only claim DTC benefit through CFMA
Terima Kasih