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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


General Definitions

(1) For the purpose of this Agreement, unless the context otherwise requires:

  • (a) the terms "one of the two States" and "the other State" mean Indonesia or Suriname, as the context requires. The term "the two States" means Indonesia and Suriname;
  • (b)
    • (i) the term "Indonesia" means the territory of the Republic of Indonesia as defined in its laws;
    • (ii) the term "Suriname" comprises the territory of Suriname and that part of the seabed and subsoil situated under the adjacent sea, over which Suriname has sovereign rights in accordance with international law;
  • (c) the term "person" includes an individual, a company and any other body of persons, which is treated as an entity for tax purposes;
  • (d) the term "company" means any body corporate or any entity which is treated as a body corporate for tax purposes;
  • (e) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
  • (f) the term "international traffic" means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State;
  • (g) the term "competent authority" means:
    • (i) in the case of Indonesia, the Minister of Finance or his authorized representative;
    • (ii) in the case of Suriname, the Minister of Finance or his authorized representative;
  • (h) the term "national" means:
    • (i) any individual possessing the nationality of a Contracting State;
    • (ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State.

(2) As regards the application of the Agreement by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the laws of that State concerning the taxes to which the Agreement applies.