Ordonansi pajak perseroan 1925 calendar

Ordonansi pajak perseroan 1925 calendar

Fezragore
28.05.2019

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Penalty charges for late payment shall not be regarded as interest for the purpose of this article. Penalty charges for late payment shall not be regarded as interest for the purpose of this article. This article shall not apply to income from research if such research is undertaken primarily for the private benefit of a specific person or persons. Gains from the alienation of any property other than that mentioned in paragraphs 1, 2 and 3 shall be taxable only in the Contracting State of which the alienator is a resident. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. Likewise, no account shall be taken towards reimbursement of actual expensesby the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission for specific services performed or for management, or, except in the case of a banking enterprise by way of interest on moneys lent to the head office of the enterprise or any of its other offices. Where a person other than an agent of an independent status to whom the provisions of paragraph 7 apply is acting in a Contracting State on behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned State in respect of any activities which that person undertakes for the enterprise, if: that person has, and habitually exercises in the first-mentioned State, an authority to conclude contracts on behalf of the enterprise; or that person maintains in the first-mentioned Contracting State a stock of goods or merchandise belonging to the enterprise from which he regularly delivers goods or merchandise on behalf of the enterprise. ARTICLE 25 Mutual Agreement Procedure Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Agreement, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.

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    the income tax imposed under the Undang-undang Pajak company tax imposed under the Ordonansi Pajak Perseroan (State Gazette No. first day of January next following the calendar year in which the latter of.

    the income tax imposed under the Undang-undang Pajak Penghasilan ( Law the company tax imposed under the Ordonansi Pajak Perseroan ( State the calendar year immediately following that in which the Convention enters. the income tax imposed under the Undang-Undang Pajak Penghasilan the company tax imposed under the Ordonansi Pajak Perseroan (State the thirtieth day of June in a calendar year after the fifth year from the date of.
    They may also consult together for the elimination of double taxation in cases not provided for in the Agreement.

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    Notification : No. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment alone or together with the whole enterprise or of such fixed base, may be taxed in that other State.

    An enterprise of a Contracting State shall be deemed to have a permanent establishment in the other Contracting State if it furnishes services, including consultancy services in that other Contracting State through employees or other personnel—other than an agent of an independent status to whom the provisions of paragraph 7 apply—provided that activities of that nature continue for the same or a connected project within the country for a period or periods aggregating more than 91 days in any twelve-month period.

    Authentication of Documents Rules, F.

    Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 43 of and section 24A of the Companies Profits Surtax Act, 7 ofthe Central Government hereby directs that all the provisions of the said Agreement shall be given effect to in the Union of India.

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    Dividends paid by a company which is resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State.

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    If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to a that permanent establishment b sales in that other State of goods or merchandise of the same or similar kind as those sold through that permanent establishment.

    While income in respect of personal activities exercised by an entertainer or an athlete in his capacity as such accrues not to the entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of article 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer of athlete are exercised.

    Done in duplicate at Jakarta this seventh day of August, one thousand nine hundred and eighty-seven in Hindi, Bahasa Indonesia and English languages, all texts being equally authentic. However, then the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph.

    Income derived by a resident of a Contracting State from immovable property, including income from agriculture or forestry, situated in the other Contracting State may be taxed in that other State. Authentication of Documents Rules, F.

    the income tax imposed under the Undang-undang Pajak Penghasilan the company tax imposed under the Ordonansi Pajak Perseroan (State on or before the thirtieth day of June in any calendar year beginning after the.

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    the income tax imposed under the Undang-undang Pajak Penghasilan under the Ordonansi Pajak Perseroan (State Gazette No. calendar year next following that in which the Agreement enters into force. Menimbang : a. bahwa persetujuan penghindaran pajak berganda dan.

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    the company tax imposed under the Ordonansi Pajak Perseroan (SState months before the end of any calendar year after the expiration of a period of .
    The provisions of paragraph 1 of this article shall also apply to profits from participation in a pool, a joint business or an international operating agency.

    If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to a that permanent establishment b sales in that other State of goods or merchandise of the same or similar kind as those sold through that permanent establishment.

    Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this article shall apply only to the last-mentioned amount.

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    Where a person other than an agent of an independent status to whom the provisions of paragraph 7 apply is acting in a Contracting State on behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned State in respect of any activities which that person undertakes for the enterprise, if: that person has, and habitually exercises in the first-mentioned State, an authority to conclude contracts on behalf of the enterprise; or that person maintains in the first-mentioned Contracting State a stock of goods or merchandise belonging to the enterprise from which he regularly delivers goods or merchandise on behalf of the enterprise.

    Where by reason of the provisions of paragraph 1, a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall settle the question by mutual agreement keeping in view its place of incorporation, place of effective management and other relevant factors.

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    Where by reason of the provisions of paragraph 1, an individual is a resident of both Contracting States, then his status shall be determined as follows: he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer centre of vital interests ; if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode; if he has an habitual abode in both States or in neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

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    Interest shall be deemed to arise in a Contracting State when the payer is that Contracting State itself, a political sub-division, a local authority or a resident of that State.

    In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the business of the permanent establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.

    In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the business of the permanent establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.

    Where a person other than an agent of an independent status to whom the provisions of paragraph 7 apply is acting in a Contracting State on behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned State in respect of any activities which that person undertakes for the enterprise, if :. The laws in force in either of the Contracting States shall continue to govern the taxation of income in the respective Contracting States except where provisions to the contrary are made in this Agreement.


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