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1 September 2021

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Synthesized Texts of Indonesia's Tax Treaties with 21 Countries as Impacted by the BEPS MLI

The synthesized texts of Indonesia's tax treaties with 21 countries as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) have been published. The synthesized texts were prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaties and the MLI take precedence and remain the legal texts applicable. The synthesized texts and the effective dates of the MLI are summarized as follows:

The MLI applies for the 1992 Indonesia-Australia tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by Australia, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 1997 Indonesia-Belgium tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by Belgium, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 1979 Indonesia-Canada tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by Canada, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 1985 Indonesia-Denmark tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 1987 Indonesia-Finland tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 1979 Indonesia-France tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by France, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 2012 Indonesia-India tax treaty:

  • with respect to taxes withheld at source in Indonesia on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to taxes withheld at source in India on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the taxable period beginning on or after 26 December 2020 (generally 1 April 2021);
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022; and
  • with respect to all other taxes levied by India, for taxes levied with respect to taxable periods beginning on or after 26 June 2021.

The MLI applies for the 1982 Indonesia-Japan tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by Japan, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 1993 Indonesia-Luxembourg tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by Luxembourg, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 2002 Indonesia-Netherlands tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by the Netherlands, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 1987 Indonesia-New Zealand tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by New Zealand, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 1992 Indonesia-Poland tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by Poland, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 2003 Indonesia-Portugal tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by Portugal, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 2006 Indonesia-Qatar tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by Qatar, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 1999 Indonesia-Russia tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 2011 Indonesia-Serbia tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by Serbia, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 1990 Indonesia-Singapore tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by Singapore, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

Note, a new income tax treaty between Indonesia and Singapore, signed in 2020, has entered into force and generally applies from 1 January 2022, although it applies in respect of taxes other than withholding taxes from 1 January 2023 in Singapore. The MLI does not impact this new treaty unless both countries notify the 2020 tax treaty as a covered agreement. Neither country has provided such notification to date.

The MLI applies for the 2000 Indonesia-Slovak Republic tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by the Slovak Republic, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 1988 Indonesia-South Korea tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by South Korea, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 1995 Indonesia-United Arab Emirates tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by the United Arab Emirates, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The MLI applies for the 1993 Indonesia-United Kingdom tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
  • with respect to all other taxes levied by the United Kingdom, for taxes levied with respect to taxable periods beginning on or after 26 June 2021; and
  • with respect to all other taxes levied by Indonesia, for taxes levied with respect to taxable periods beginning on or after 1 January 2022.

The synthesized texts linked above were issued via circular letters from Indonesia's Directorate General of Taxation and published by a third party.

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