(5a) The tax rate applicable as referred to in paragraph (5) for unregistered resident Taxpayer

is 20% (twenty percent) higher than those registered resident Taxpayer.

(6) Deleted.
(7) Deleted.
(8) Regulation concerning guidelines for withholding of tax on income in connection with any
employment, services, or activity shall be stipulated by or based on the Minister of
Finance Regulation.

17. The provisions of paragraph (1) and paragraph (2) of Article 22 are amended, and 1 (one)
paragraph is added to, which is paragraph (3), so that Article 22 is as follows:

Article 22

(1) The Minister of Finance may designate:

a. government treasurers to withhold tax in connection with payment for supply of
goods
b. certain entities to withhold tax from Taxpayer who conduct in import activities or
other business activities; and
c. certain entities to withhold tax from Taxpayer who purchase very Luxurious Goods.
(2) Regulations governing the tax base for withholding purposes, the criterion, the
characteristic and amount of withholding of taxes as referred to in paragraph (1), shall be
stipulated by or based on the Minister of Finance Regulation.
(3) Withholding tax rate as referred to in paragraph (2) for unregistered resident Taxpayer is
100% (one hundred percent) higher than those registered resident Taxpayer.

18. The provisions of paragraph (1), paragraph (2), and subparagraph c of paragraph (4) of Article
23 are amended, sub paragraph d and subparagraph g of paragraph (4) are deleted, and 1(one)
paragraph is inserted between paragraph (1) and paragraph (2), which is paragraph (1a), so
that Article 23 is as follows:

Article 23

(1) The following income, in whatever name and form, paid, apportioned to be paid, or on the
due date of payment by a government institution, a resident taxable entity, a person who
organizes an activity, a permanent establishment or a representative of any other non-
resident enterprises to a resident Taxpayer or permanent establishment, shall be subject
to withholding tax of:
a. 15% (fifteen percent) of the gross amount of:
1. dividends as referred to in paragraph (1) subparagraph g of Article 4;
2. interest as referred to in paragraph (1) subparagraph f of Article 4;
 3. royalties; and
4. prizes and awards, bonus, and similar payments other than those that have been
withheld under paragraph (1) subparagraph e of Article 21;
b. Deleted;
c. 2% (two percent) of the gross amount of:
1. rent and other income in connection with the use of property, except rent and
other income in connection with the use of property that have been withheld
under paragraph (2) of Article 4;
2. compensation in connection with technical, management, construction,
consultation and other services, except those that have been withheld under
Article 21;
(1a) Withholding tax rate as referred to in paragraph (1) for unregistered resident Taxpayer is
100% (one hundred percent) higher than those registered resident Taxpayer.
(2) Further Regulation related to other services as referred to paragraph (1) subparagraph c
(2) shall be stipulated by or based on the Minister of Finance Regulation.
(3) An individual who is a resident Taxpayer may be appointed by the Director General of
Taxes as a withholding agent as referred to in paragraph (1).
(4) Withholding tax as referred to in paragraph (1) shall not apply to:
a. income paid or owed to a bank;
b. lease payment in finance lease agreements;
c. dividends as referred to in paragraph (3) subparagraph f of Article 4 and dividends
received by individual taxpayers as referred to in subparagraph (2c) of Article 17;
d. deleted;
e. distributed profit as referred to in paragraph (3) subparagraph i of Article 4;
f. profit which is distributed by a cooperative to its members;
g. deleted;and
h. income paid or payable to a financial service entity which serves as a loan
intermediary and/or financing stipulated by the Minister of Finance Regulation;

19. The provisions of paragraph (3) and (6) of Article 24 are amended so that Article 24 is as
follows:

Article 24

(1) Tax paid or tax payable in foreign countries on offshore income by resident Taxpayer may
be credited in the same taxable year against the tax payable under this Law.
(2) The amount of allowable tax credit as referred to in paragraph (1) shall be equal to the
amount of foreign tax, but shall not exceed the tax payable calculated under this Law.
(3) In calculating the limit of allowable tax credit, the source of income shall be determined as