TTM 5 - Withholding Tax Article 4 (2) and 15

COLLECTION WITHHOLDING
Income tax
• Article 26
• Article 4(2)
• Article 15
ENDAH MIRASANTY,
SH,SE.,Ak.,M.Ak.,CA.,BKP
2
Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

1. Law Number 11 of 2020 concerning Job Creation 2. Minister of Finance
LEGAL BASIS
Regulation Number 258/PMK.03/2008 concerning Withholding Income Tax Article 26 on Income from the Sale or Transfer of Shares as Meant in Article 18 Paragraph (3c) of the
Tax Law Income Received Or Obtained by Foreign Taxpayers
3. Regulation of the Minister of Finance Number 82/PMK.03/2009 concerning Regulation of the Minister of Finance regarding Withholding Tax Article 26 on Income from the Sale
or Transfer of Assets in Indonesia, except as regulated in Article 4 Paragraph (2) of the Income Tax Law Received Or obtained by foreign taxpayers other than permanent
establishments in Indonesia
4. Regulation of the Minister of Finance Number 14/PMK.03/2011 Concerning Tax Treatment of Taxable Income After Deduction Taxes of
a Permanent Establishment.
5. Regulation of the Minister of Finance Number 39/PMK.011/2013 concerning Obligations with Withholding and/or Collection of Income Tax Payable to Other Parties by
Companies that are Bound by Production Sharing Contracts, Contracts of Work, or Cooperation Agreements on Mining Operations 6. Regulation of the Minister of Finance
Number 202/
PMK.010/2017 Concerning the Implementation of Income Tax Treatment Based on Provisions in International Agreements 7. Regulation of the Minister of Finance
Number 236/PMK.010/2020 concerning
Amendments to Regulation of the Minister of Finance Number 202/PMK.010/2017
Concerning the Implementation of Income Tax Treatment Based on Provisions in International Agreements
8. Decree of the Minister of Finance Number 624/KMK.04/1994 concerning Withholding Income Tax Article 26 on Income in the Form of Premiums
Insurance and Reinsurance Premiums Paid to Insurance Companies Overseas 9. Decree of the Minister of
Finance Number 434/KMK.04/1999 concerning Withholding Income Tax Article 26 on Income Received or Earned by Foreign Taxpayers Other than Permanent
Establishments on Income in the Form of Profits from Sales of Shares 10. Regulation of the Director General of Taxes Number PER - 16/PJ/2011
Concerning Procedures for Notifying Taxpayers of Permanent Establishment
Reinvestment of Taxable Income After Tax is Deducted
11. Regulation of the Director General of Taxes Number PER - 25/PJ/2018 concerning Procedures for Applying Double Taxation Avoidance Agreements 12. Circular
Letter of the Director General of Taxes Number SE - 22/PJ.22/1988 Concerning Income Tax Article 26 on Foreign Credit Interest 13.
Circular Letter of the Director General of Taxes Number SE - 23/PJ.43/1995 Concerning Explanation of Instructions for Withholding Income Tax Article 21 and Article 26 (Series PPh Article
21 Number 4)
14. Circular Letter of the Director General of Taxes Number SE - 25/PJ.4/1995 Concerning Withholding Income Tax Article 26 on Payment of Insurance Premiums to Overseas
(PPh Series Article 23/26 Number 5)
15. Circular Letter of the Director General of Taxes Number SE - 04/PJ.34/2005 Concerning Guidelines for Determining "Beneficial Owner" Criteria As Listed in
the Avoidance of Double Taxation Agreement between Indonesia and other countries
16. Circular Letter of the Director General of Taxes Number SE - 57/PJ/2015 Concerning Affirmation of Tax Withholding and/or Collection Treatment
Income Based on the Regulation of the Minister of Finance Number 39/PMK.011/2013 Concerning the Obligation of Withholding and/or Collection of Income Tax Payable to
Other Parties by Companies Bound by Production Sharing Contracts, Contracts of Work, or Cooperation Agreements on Mining Businesses
17.Circular Letter of the Director General of Taxes Number SE - 19/PJ/2016 Concerning Procedures for Implementation of International Tax Activities 18. Circular Letter of
the Director General of Taxes Number SE - 04/PJ/2017 concerning Determination of Permanent Establishment for Foreign Tax Subjects Who
Providing Application Services and/or Content Services via the Internet

4
PER 25/PJ/2018
REGULATION OF THE DIRECTOR GENERAL OF TAXES

ABOUT THE IMPLEMENTATION PROCEDURE
TAX AVOIDANCE AGREEMENT
DOUBLE (P3B)

TABLE OF CONTENTS
BENEFITS & OBLIGATIONS

LEGAL BASIS
EXCESS RETURN PROCEDURES

CUTTING AND/OR FORM FILLING PROVISION
TAX COLLECTION GENERAL & SPECIAL
DGT
IMPLEMENTATION OF P3B IN INDONESIA

Machine Translated by Google
GENERAL PROVISIONS
&
B
SPECIAL

P3B BENEFITS
WPLN who receive and/or earn income from Indonesia can obtain P3B
Benefits in accordance with the provisions stipulated in
P3B with the following conditions:
ÿ Income recipients are not Indonesian domestic tax subjects ;
ÿ Recipients of income are individuals or entities that

is a domestic tax subject from a partner country or partner jurisdiction
P3B;
ÿ There is no misuse of P3B; And
ÿ The recipient of the income is a Beneficial Owner, in terms of

required in P3B

LIABILITY OF WITHDRAWAL AND/OR
TAX COLLECTION

9
P3B IMPLEMENTATION METHOD

10
P3B IMPLEMENTATION SCHEME

11
ÿ Using the DGT form, filled in correctly,

completely and clearly
ÿ Signed by WPLN
SURA T ÿ AUTHORIZED by being signed or an

INFORMATION N equivalent sign by an authorized official
according to custom or by C o R
DOMICILE (Certificate of Residence)
ÿ There is a statement that WPLN does not occur

misuse of P3B
ÿ Used for the same period

listed in SKD and valid
12 months at most

CERTIFICATE OF RESIDENCE
Is a certificate with any name explaining the status of resident

(resident) for tax purposes for WPLN issued and ratified by an
Authorized Officer from a P3B partner country or jurisdiction of
the P3B partner in the context of implementing P3B.
using English;
At least include information regarding the name of

the WPLN, date of issue, and tax year when the
Certificate of Residence is valid; And
Include name and signed or given a sign equivalent to a signature by

the Authorized Official in accordance with the custom in the partner
country or jurisdiction of the P3B partner.
It is still mandatory to fill out the DGT Form
12
13
HOW TO FILL THE FORM – DGT

14
HOW TO FILL THE FORM – DGT

15
ATTACHMENT
NUMBER: PER-/PJ/2018
CONCERNING: PROCEDURES FOR IMPLEMENTING THE APPROVAL OF TAX
AVOIDANCE
DOUBLE

16
ATTACHMENT
NUMBER: PER-/PJ/2018
CONCERNING: PROCEDURES FOR IMPLEMENTING THE APPROVAL OF TAX
AVOIDANCE
DOUBLE

17
TRANSITIONAL PROVISIONS

18

19
FINAL income tax
Characteristics :
• immutable, •
Expenditure in
Can not be credited obtaining income (Final PPh Income Tax which is
Against Total PPh object) in question may completed, finished, irrevocable,
owed not be financed fiscally final
• end of
series/process

FINAL Income Tax Article 4 (2)
This income is given separate treatment. This treatment includes the
nature, amount, and procedures for implementing payments, deductions
Type Consideration
ÿ Ph. Deposit Interest and Tab.

Encouragement in
the development of
Community
ÿ Ph. Lottery prize investment &
savings
Reduced
simplicity administrative
ÿ Ph. Share Transactions
burden on
• Ph. Transfer of Assets taxpayers / tax authorities
land/building, Jackson, Real Equity
Estate, Rent
Tax Imposition
• Certain Ph. Others
Consider development
Economics and Monetary
20
Construction service
Land Transfer /
Bang
Active Income Transfer of Shares

Venture Capital
OP DN dividend Rent Land / Bang
Bond Interest Sales of Shares
Derivative Transactions
hbajet ct
Wistsou
Cooperative interest
OBJECT
Types of Income Subject to Final Income Tax
SPN discount
Flower
Tab/Deposit/SBI
Lottery
prize
22
PP 9 of 2022
SECOND AMENDMENT TO RULES
GOVERNMENT NUMBER 51 OF 2008
ABOUT THE INCOME TAX
INCOME FROM SERVICE BUSINESS
CONSTRUCTION
CONSTRUCTION SERVICES
Construction consulting services
SERVICE
and/or construction work
Service
CONSTRUCTION
Providers who
have small Work Construction
qualification Construction Integrated Integrated Construction
Work consulting
business by uncertified consulting
Construction other construction work construction work services by
entity services by uncertified
than number 1 & by certified by non-certified
certificates business certified
2 (2.65%) service service providers service providers (6%)
or work entities or service providers (3.50%)
providers (2.65%) (4%)
competency in
certificates for div
individual businesses (1.75%)
idu
als
(4
%)
RATES x TOTAL PAYMENTS OR TOTAL RECEIPTS
IT IS PART OF THE CONTRACT VALUE NOT INCLUDING VAT

DIFFERENCE (PP Number 34 of 2016 jo. PMK No 261/ PMK.03/2016)
Transfer of Land &/ Building Rights
Income Diversion
Income from the transfer of land It can occur due to sales,
&/ building rights is levied exchanges, grants, or other
PPh at the time of the means including land use, waiver,
transaction transfer of rights, auction
Evidence
of Deed
Notary
Public
RATES
Transfer Value
value based on the decision of the authorized official, value according to
• 1% of the gross amount of
•
• minutes of auction, in the case of transfer of rights in accordance with
auction regulations (Vendu Reglement Staatsblad of 1908 Number 189
the RS transfer, and RSS
and its amendments); the value that
should have been received or obtained, in the event that the transfer of
• 2.5% of the gross amount
•
rights over land and/or buildings is carried out through a sale and of the transfer
purchase that is influenced by a special relationship,
the value actually received or obtained, in the case that the transfer of rights
•
over land and/or buildings is carried out through a sale and purchase that is
not affected by a relationship preferential value that should be received or
obtained based on market prices, in the event that the transfer of rights over
•
land and/or buildings is carried out through exchange, waiver, transfer of
rights, grants, inheritance, or other methods agreed between the parties

Excluded from the 24
obligation to pay/collect PPh is
an individual who has income below Non-Taxable Income who transfers rights over land and/or buildings with a gross transfer amount of less than Rp.
60,000,000.00 (sixty million rupiah) and is not a broken amount;
individual who transfers assets in the form of land and/or buildings by means of grants to blood relatives in one degree straight lineage, religious bodies,
educational bodies, social organizations including foundations, cooperatives or private persons who run micro and small businesses, the provisions of which are
regulated further with the Regulation of the Minister of Finance, as long as the grant has no connection with business, work, ownership, or control between the
parties concerned;
entities that transfer assets in the form of land and/or buildings by way of grants to religious bodies, educational bodies, social agencies
including foundations, cooperatives or individuals who run micro and small businesses, the provisions of which are further regulated by a Minister of Finance
Regulation, as long as the grant is there is no relationship with business, work, ownership, or control between the parties concerned;
transfer of assets in the form of land and/or buildings due to inheritance;
the entity that transfers assets in the form of land and/or buildings in the framework of a business merger, consolidation or expansion that has been determined
by the Minister of Finance to use book value;
an individual or entity that transfers assets in the form of buildings in the framework of implementing a contract for transfer of use, transfer of use for use, or
utilization of state property in the form of land and/or buildings; or
an individual or entity that is not a tax subject that transfers assets in the form of land and/or buildings.

TRANSFER OF LAND / BUILDING
PP 34 of 2016
TRANSFER OF KPD Transfer to the Government for

GOVERNMENT Public Interest Requiring Requirements
Special :
1. for public roads, sewers,

reservoirs, dams, irrigation canals, seaports, airports
Does not require special and public safety facilities, as well as TNI/ POLRI
conditions facilities
gross amount above

60 Million
NOT CUT
Income tax rate of 2.5% :
Treasurer cut Gross Amount Transfer Value Based
Before Payment Ybs Official Decision (Final)
25
26
WP LN
in the form
Deposit
Income Savings
Flowers in shape
SBI
whatever
Final Income Tax at a
rate of 20% of
FLOWER the gross amount /
according to the tax treaty
subjected
Rates of 20% of Gross Ph
FINAL income tax
PP 131 of 2000; KMK 51/KMK.04/2001

27
Exceptions Withholding is made against.
1 The amount of Deposits/Tab/SBI is no more than 7.5

Bank interest
Million
Even though interest is received
The Bank is not deducted from
2EXCEPTION
Interest received Banks established in
Indonesia
the Final Income Tax, which
does not mean that the interest is
CUTTING exempt from taxation , but the

tax imposition of this interest income is
Tab interest on government banks in the context of 3
through a self-payment
ownership of RSS/Rusunami
mechanism through Article Income
Tax
25/Article 29
4 Interest on Deposits/Tab/SBI received
Pension fund

28
Person Body With

Body Ownership
Personal
Private Person
Those who rent out land and or buildings
Subject to Income Tax Article 4(2) which is final, in the amount of
10% 10% 10%
FROM GROSS AMOUNT OF RENTAL VALUE PP 34 of 2017

•All Amounts Paid / Payable By Tenants With Name And In
Any Form Relating to Land and/ or Leased Buildings Including •Maintenance Fees;
Maintenance cost; Security cost; Other Facility Fees
And a good service charge whose agreement is made separately/ unified

SPN
Letter of the state Treasury
CERTAIN INCOME
CUTTING
• SPN discount
worn
• Withholding PPh KNOWN NO

right
Characteristic
• FINALS
PPh 26 20%
Accepted by
or
Final PPh 20% banks, pension
depending on funds, mutual
the funds
tax treaty

30
VENTURE CAPITAL COMPANIES

INCOME
Sales of Shares Transfer of Capital Participation
At the Business Partner Company

Small, medium (Sector determined by Shares are not traded in
the Minister of Finance) Exchange
SUBJECT TO FINAL TAX
0.1% Total Gross Income

BOND
12 month term of Government Bonds
INCOME IN THE FORM OF BONDS INTEREST
Bond interest with Discount from Interest-free bond Accepted

Accepted
coupons Bond discount mutual funds
•15% WP DN / BUT •15% WP DN / BUT •15% WP DN / BUT •0% : 2009 - 2010 •Banks
•20% / Tax Treaty •20% / Tax Treaty •20% / Tax Treaty •5% : 2011 - 2013 •Pension Funds
SPLN SPLN SPLN •15% : 2014
Gross amount The difference between the selling price No

and the acquisition cost (excluding cut
according to ownership current interest) (
SK
B)

32
PRIZES
PRESENT
Award,
Prizes from DRAW LOT Race,

Job, Kegt
sweepstakes /
jobs / activities
and awards are objects FINAL VAT 25% Body OP SPLN
Tax
Article 23 15% Article 21 Article 26
**Withholding Income Tax does not apply to direct prizes in the sale of goods or services as long
as they are given to all buyers or end consumers without a draw and the prizes are received
directly by the end consumers when purchasing goods or services

COOPERATIVE INTEREST
Not included in this definition are interest on deposits received by individual cooperative
members which are part of the remaining business results.
PP 15 of 2009
Income in the form of interest on deposits paid by cooperatives established in
Indonesia to individual cooperative members is subject to final income tax.
0%
income in the form of deposit interest up to IDR 240,000.00
10%
of income in the form of interest on deposits of more than IDR
240,000.00 (two hundred and forty thousand rupiah) per month
Provision
Cooperatives are required to deduct final Income Tax
at the time of payment.

Example of Income Tax calculation on deposit interest:
• Interest paid in February Rp. 240,000.00 for the January period, then PPh
payable is 0% x Rp. 240,000.00 = Rp. 0.00
• Interest paid in February Rp. 245,000.00 for the January period, then the PPh
payable is 10% x Rp. 245,000.00 = Rp. 24,500.00
• Interest is paid in April in the amount of IDR 500,000.00 with details of:
January IDR 250,000.00
February IDR 150,000.00
March IDR 100,000.00
Then what is subject to 10% PPh is:

January interest of 10% x IDR 250,000.00 = IDR 25,000.00 and for
February and March IDR 0.00.
35
Transaction Income
SHARE Sale of Shares in BE

Final PPh is collected by
Sales on the Exchange BE organizers
Not Founder's Stock

0.1% X Sales Transaction Value
Rates Founder's Share:

• 0.1% X Transaction Value
Sales, plus • 0.5% X
Market Value of Shares at
IPO
Endah Mirasanty SH, SE., Ak., M. Ak.,

CA, BKP PP 14 Years. 199
FOUNDER SHARE
What is meant by "founder" is an individual or entity whose name is recorded in the Register of
Shareholders of the Limited Liability Company or listed in the Articles of Association of the Limited
Liability Company before the Registration Statement is submitted to the Capital Market Supervisory
Agency (Bapepam) in the context of an initial public offering . be effective.
Included in the definition of "founder" is an individual or entity that receives the transfer of shares
from the founder due to:
•
• inheritance; grants that meet the requirements of Article 4 paragraph (3) letter a number 2 Law Number
7 of 1983 concerning Income Tax as last amended by Law Number 10 of 1994;
other ways that are not
• subject to Income Tax at the time of the transfer.
What is meant by "founder's shares" are shares owned by those who fall into the category of
"founders" as referred to above.
Included in the definition of "founder's shares" are: 1.

shares acquired by the founders originating from the premium capitalization issued after the initial
public offering (initial public offering); 2.
shares originating from the stock split of the founder.
36
FOUNDER SHARE
Not included in the definition of "founder's share" are: 1.

shares acquired by the founders from the distribution of dividends in
the form of shares;
2. shares acquired by the founder after the initial public offering originating from the
exercise of pre-emptive rights (right issue), warrants, convertible bonds and other
convertible securities;
3. shares acquired by the founder of the Mutual Fund company.
37
38
PP 131/2000
WIDODO does not have a NPWP and has a trading business. He has a personal deposit of IDR 100,000,000 which is
kept at BANK KAYA RAYA. Per May 17, 2011 earned interest of IDR 2,000,000. Upon
payment of the deposit interest, then... a. BANK KAYA RAYA deducts Article 4(2) Income Tax by 20% b. BANK KAYA
RAYA deducts Article 4(2) Income Tax by 20% plus 20%
additional because they do not have an NPWP

c. BANK KAYA RAYA is not subject to PPh deductions because interest payments are below IDR
7,500,000 d. BANK
KAYA RAYA is not subject to PPh deductions because it is not an object
Cutting
answer: PP 131/2000 deposit interest

is not payable if the deposit is not more than 7,500,000

39
PP 131/2000
PT BPR Desa Maju has a deposit of IDR 1,000,000,000 which is kept at BANK
MANDIRI. As of May 1, 2013 earned interest of IDR 2,500,000. Upon payment of
the deposit interest, then... a. BANK MANDIRI cuts Income Tax Article 4(2) by
20% b. BANK BPR DESA MAJU cuts Income
Tax Article 4(2) by 20% c. BANK MANDIRI is not subject to PPh deductions
because interest payments are below IDR 7,500,000 d. BANK
MANDIRI is not subject to

PPh deductions because it is not an object
Cutting
Answer: PP 131/2000
Because the owner of the deposit is a bank

40
PT Ada Aja rented a house owned by H. Sahili in the Teuku Umar Denpasar area to
be occupied by Mr. Alex Hleb, an expatriateemployee. The
agreed rental price is IDR 50,000,000 for a year's rental period. Mr. Sahili cannot show
his NPWP card at the time of withholding tax. The type of PPh deduction, the amount of
PPh withheld, and the method of payment is...
a. PPh Article 23, IDR 5,000,000 paid by H. Sahili

b. PPh Article 23, IDR 10,000,000 deducted by PT Ada Aja
c. Final Income Tax Article 4 (2), IDR 5,000,000 is deducted by PT Ada Aja
d. Final Income Tax Article 4 (2), IDR 10,000,000 is deducted by PT Ada Aja

41
PT Adi Tok, a Construction Planning Company that has obtained and does not yet
have certification, carries out construction work for the construction of
Roy's private building with a contract value of IDR 300,000,000,
how much PPh is payable, and who makes the deductions… a. Final PPh 4
paragraph 2 of Rp.
12,000,000 and deducted by PT Adi Tok b. Final PPh 4 paragraph 2 of Rp.
12,000,000 and deducted by Roy c. Final PPh 4 paragraph 2 of Rp.
6,000,000 and cut by PT Adi Tok d. Final PPh 4 paragraph 2 of Rp. 6,000,000 and
was deducted by Roy

42
PT Hotel Bali leases room for an ATM machine to PT Bank Gitu Aja Tbk which is paid monthly,
the rental value consists of the room and electricity bill for IDR 10,000,000 and electricity bill for IDR.
200,000 per month, how much PPh is owed and who has the obligation to cut it..... a. Final PPh 4 paragraph 2
for land and/or building rental of Rp.
1,000,000 and
cutting PT Bank Gitu Aja Tbk
b. Final PPh 4 paragraph 2 for land and/or building rental of Rp. 1,020,000 and
cutting PT Bank Gitu Aja Tbk
c. Final PPh 4 paragraph 2 for land and/or building rental of Rp. 1,000,000 and PT Hotel Bali
deductible d. Final PPh 4
paragraph 2 for land and/or building rental of Rp. 1,020,000 and cutting PT Hotel Bali

43
Trading business Forward Undaunted (Harry) registered at KPP Pratama Jakarta Pulogadung has
a trading business trading retail building materials. UD Maju Undaunted (09.888.777.0-
073.000) uses bookkeeping in carrying out its tax obligations.
The transactions carried out are: 1.
Paying a warehouse rental fee of Rp. 9,000,000, the payment recipient is Widodo (non-NPWP)
2. Paid a party equipment rental fee of IDR 6,000,000. Payee is Wajinah (non NPWP)
3.Paying a notary fee of IDR 15,000,000, the recipient of the payment is Firma Waginah, SH
(02.444.555.6-001.000)
For the warehouse rental payment of IDR 9,000,000…. a. UD Maju
Undaunted must deduct PPh Article 4 paragraph (2) of IDR 900,000 b. UD Maju
Undaunted must deduct PPh Article 4 paragraph (2) in the amount of IDR 900,000 if it has received a
determination as a withholding tax from the head of KPP Pratama Jakarta Pulogadung
c. UD Maju Undaunted is not a tax cutter because it is an individual taxpayer d. There is no correct answer
Answer: Article 1 and Article
3 KEP-50/
PJ/1996

44

BASE
PPh Article 15
Special Calculation Norms for calculating net income from Certain Taxpayers
KMK 417/KMK.04/96 foundation

based on practical considerations or in accordance with the prevalence of tax imposition in these
business fields, the Minister of Finance is authorized to determine Special Calculation Norms to
calculate the amount of net income of certain Taxpayers
CERTAIN Taxpayers
international shipping or airline companies, foreign insurance companies, oil, gas and
geothermal drilling companies, foreign trading companies, companies that make
investments in the form of build, operate, and transfer ("build, operate, and transfer")

46
The Minister of Finance Decree (KMK) that is

still valid regulates PPh 15:
1. KMK Number 433/KMK.04/1994 concerning Norms for Special Calculation of Taxable Income on Income from
Employment Received by Foreign Workers Working for WP Oil and Gas Drilling Agencies
in Indonesia;
2. KMK Number 634/KMK.04/1994 concerning Norms for Special Calculation of Net Income for Taxpayers
Overseas with a Trade Representative Office in Indonesia;
3. KMK Number 284/KMK.04/1995 concerning PPh Treatment of Parties Collaborating in the Form of a Build
Operate Transfer Agreement or BOT;
4. PMK Number 475/KMK.04/1996 concerning Norms for Calculation of Net Income for Taxpayers of
Domestic Aviation Companies;
5. KMK Number 543/KMK.030/2001 concerning Norms for Special Calculation of Net Income and Income Tax
Payment Methods for Taxpayers Conducting International Contract Manufacturing Services in the Production of
Children's Toys.

47
TYPES OF INCOME TAX (PPH) ARTICLE 15 ACCORDING TO

APPLICABLE POLICIES, WHICH ARE:
Income Tax (PPh) Article 15 on domestic flight charters
Income Tax (PPh) Article 15 on domestic shipping
Income Tax (PPh) Article 15 on overseas shipping or flights
Article 15 Income Tax (PPh) on foreign trading area offices in

Indonesia
Income Tax (PPh) Article 15 on Taxpayers who carry out business activities of
international tolling services in the production of children's toys.

48
Person Founded and domiciled
Personal in Indonesia
Income from the

Doing business transportation of
cruise by ship people and/ or
goods
CRUISE
CINSOIDEUBONDY • Registered in Indo/LN • /with Income
other party's ship from
TRY boat rental
Indo port to other ports in Indo
Indo port to Indo outer port
Indo Outer Port to Indo port
Indo outer port to Indo outer

port

TAX OBTAINED
“Deemed Profit PPh”
Income Norm Income
Gross 4% Net
TAX is FINAL Gross Income X 1.2%
[ Gross income]
Gross Income is all compensation or replacement value in the form of money or
money value received or earned by domestic shipping company Taxpayers
from the transportation of people and/or goods loaded from one port to another in
Indonesia and/or from ports in Indonesia to foreign ports and/or vice versa

REDEMPTION
INCOME
At the time of payment / Provide Proof of Withholding
payable compensation / to the Party receiving
replacement value. the income.
Derived from direct

Cut PPh Certificate of withholding tax
service users
PASSENGER
Report Paying PPh

PAID SELF
At the latest on the 15th
Report using Periodic SPT Deposit PPh to the Bank
facilities no later than the Perception / POS & Giro Office
20th of the following month no later than the 10th of the
following month
There is a rental/charter agreement with

the withholding tax, the paying party Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP
51
FLIGHT
DOMESTIC
Position in
Company
Earnings
from Charters
Indonesia
Net Income 6% of Ph. Gross
The amount of Income Tax is 1.8% of Gross Circulation
KepMenkeu 475/KMK.04/1996

52
SHIPPING AND
FLIGHT
international
Must Doing
Tax Shipping &/ domiciled

business at BUT
Flight Abroad
Gross circulation of all replacement

values or compensation in the form of
money or money value from the
transportation of people and/or goods
loaded from one port to another port
in Indonesia and/or from a port in
Indonesia to a port KMK 417/ KMK.04/1996
abroad

TA
X Circulation
Gross
Circulation
Gross
Norm Rates
Income Tax
Norm TAX 2.64
6% Net Income
F %
inal
s
Tax
Net PH owed
Cutting Reporting Payment

Same with the Same with the Same with the
previous previous previous
mechanism mechanism mechanism

54
Built Operate BOT

& Transfers
During
Period “The building handed over
by the investor to the
Agreeme
holder of land rights is
nt
Income"
For this income, final

Building income tax is payable of 5%
Cooperation Divert
of the highest value
rights Building
agreement between the NJOP and the
market price
Buildings can be RUKO,
Which states that To land RUKAN, Hotels,
the right holder Land rights holders shopping centers or
grants rights to after the
rights holder other buildings
INVESTORS with agreement
investors ends

55
COMPANY MACLOON SERVICES

FOREIGN TRADE INTERNATIONAL
for net income = 1% x gross exports to for net income = 7% x gross turnover
Indonesia
for income tax payable = the highest

Income tax payable = 0.44% x gross
and final exports rate of article 17 x net income.
KepMenkeu 634/ KepMenkeu 543/

KMK.04/1996. KMK.03/2002

56
ESSAY
In October 2012 PT Kolang Kaling made the following transactions/payments: Paid 2011
dividends
of Rp. 10,000,000,000 each to Mr. Ali (10% shareholder), PT Angin Ribut (20% share),
Koperasi Mitra Guna (20% share), CV Pangrango (30% share) and Tuan Maun San (Myanmar
citizen, 20% share); Paid interest to Bank BCA on loans received at the beginning
of 2012 amounting to Rp 5,000,000; Paid heavy equipment rental to PT Teknika Cipta in the
amount of IDR 20,000,000
for the next year's rental period; Paid the third term audit fee to the Public Accounting Firm
on behalf of Rizal Syamsi and
Partners in the amount of Rp. 20,000,000.
Question :
Calculate the income tax payable for the transaction above...

57
SEE YOU NEXT WEEK

COLLECTION WITHHOLDING
ESSAY ASSIGNMENT DISCUSSION

Description Currency Mark
cost USD 500,000
Insurance USD 10,000
freight USD 40,000
Import Duty USD 110,000

(20%)
PT AJUS AJAN on August 27 2020 bought goods to the United States at a price of USD
500,000. it is known that the company has an API issued by the trade department and at the
time of purchase the KMK exchange rate was IDR 8,000 per USD.
1. Based on this information, calculate the PPh 22 payable 2. And on the

same day the company's partner, namely PT DON'T BE YOU, buys the same goods, but the
company does not have an API. Then how is Income Tax 22 owed?
59
Endah Mirasanty
SH,SE.,Ak.,M.Ak.,CA,BKP
Answer :
1. CIF = 550,000 USD
Import Duty (20%) = 110,000 USD
550,000 USD + 110,000 USD = 660,000 USD (Import Value)

660,000 USD X 8,000 Working Capital Rate = Rp. 5,280,000,000 ( Import Value ) Rp.
5,280,000,000 X 2.5% = Rp. 132,000,000 (Article 22 Income Tax Outstanding)
2. Based on the example above, for example, PT DON'T BE YOU (does not have API ) imports the
same goods again, the payable PPh Article 22 is: Rp. 5,280,000,000 X 7.5% = Rp. 396,000,000
60
Endah Mirasanty
PT PRAMANA (first party) entered into a contract with PT EMIR an advertising
agency company (Second Party) to make advertisements as well as placing
advertisements at PT AGUNG (Third Party). The agreed contract value is IDR
103,000,000. in the billing note is specified as follows; 1.
Purchase of advertising materials of Rp. 5,000,000
2. Consulting services of Rp. 5,000,000
3. Agent management fee of Rp. 3,000,000 4.
Cost of advertising to media companies Rp. 90,000,000
Calculate
4. Withholding PPh 23 made by PT EMIR for the cost of advertising to PT AGUNG
5.Withholding PPh 23 made by PT PRAMANA for payment of consulting

services and agency services to PT EMIR 3.
How is PPh 23 deducted if PT EMIR has no supporting evidence for the details of the
bill?
61
Endah Mirasanty
Answer :
1. Deductions made by PT EMIR on payment for advertising services to
the company PT AGUNG in the amount of: 2%
X Rp. 90,000,000 = Rp. 1,800,000
2. Deductions made by PT PRAMANA for payment of consulting
services
and agency services to PT EMIR is in the amount of:
2% X Rp. 5,000,000 = Rp. 100,000 for consulting services and,
2% X Rp. 3,000,000 = Rp. 60,000 for agency services
3. In the event that there is no supporting evidence for the details of the invoice above,
the amount used as the basis for withholding PPh Article 23 is Rp.
103,000,000 so that the PPh Article 23 which PT PRAMANA deducted for payment to PT EMIR
is: 2% X
Rp. 103,000,000 = Rp. 2,060,000
62
Endah Mirasanty
Oman, BKP (06.555.888.9-xxx.000) has cash of IDR 10,000,000,000.
You are asked to analyze how much investment Oman BKP (net tax) will receive
at the end of 2012. The investment data that has been made during 2012 is: a)
Purchased a luxury sedan vehicle
for IDR 1,000,000,000 and
leased to PT HHH and receive rental payments of IDR 100,000,000 per year (not
including tax). Payment received on January 17, 2012
b) Purchased shares in a public company for IDR 2,000,000,000 on January 4,

2012. Shares were sold on December 19, 2012 for IDR 2,200,000,000
c)Purchased PT DDD (a non-
listed trading company) for IDR
5,000,000,000 on 18 February 2012. PT DDD distributed dividends worth Rp
90,000,000 on 09 October 2012
d) Bought an apartment for IDR 1,500,000,000 on November 7, 2012 and
leased it to PT HHH for IDR 150,000,000 (excluding tax). Payment received
December 18, 2012.
Calculate the PPh payable for the transaction mentioned above?

63
Endah Mirasanty
Answer:
a) deducted from vehicle rental income (PPh Article 23)
Rp. 100,000,000 X 2% = Rp. 2,000,000 b) The
profit on the sale of shares is deducted (PPh Article 4 paragraph 2)
Rp. 2,200,000,000 X 0.1% = Rp. 2,200,000
c) Payment of dividend income - not reinvested
(PPh Article 4 paragraph 2)
Rp. 90,000,000 X 10% = Rp. 900,000

d) deducted from building rental income (PPh Article 4 paragraph 2) Rp.
150,000,000 X 10% = Rp. 15,000,000
So for net income after deducting taxes obtained by Mr
Oman is
Received income = Rp. 540,000,000

Tax = Rp. 20,100,000
Rp. 519,900,000
64
Endah Mirasanty

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COLLECTION WITHHOLDING

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

REGULATION OF THE DIRECTOR GENERAL OF TAXES

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

BENEFITS & OBLIGATIONS

EXCESS RETURN PROCEDURES

IMPLEMENTATION OF P3B IN INDONESIA

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

ÿ Income recipients are not Indonesian domestic tax subjects ;

ÿ Recipients of income are individuals or entities that

ÿ There is no misuse of P3B; And

ÿ The recipient of the income is a Beneficial Owner, in terms of

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

P3B IMPLEMENTATION METHOD

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

P3B IMPLEMENTATION SCHEME

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

ÿ Using the DGT form, filled in correctly,

SURA T ÿ AUTHORIZED by being signed or an

ÿ There is a statement that WPLN does not occur

ÿ Used for the same period

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Is a certificate with any name explaining the status of resident

At least include information regarding the name of

Include name and signed or given a sign equivalent to a signature by

It is still mandatory to fill out the DGT Form

HOW TO FILL THE FORM – DGT

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

HOW TO FILL THE FORM – DGT

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

FINAL income tax

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

ÿ Ph. Deposit Interest and Tab.

Active Income Transfer of Shares

OP DN dividend Rent Land / Bang

Bond Interest Sales of Shares

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

obligation to pay/collect PPh is

transfer of assets in the form of land and/or buildings due to inheritance;

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

TRANSFER OF KPD Transfer to the Government for

1. for public roads, sewers,

gross amount above

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Exceptions Withholding is made against.

1 The amount of Deposits/Tab/SBI is no more than 7.5

CUTTING exempt from taxation , but the

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Person Body With

Those who rent out land and or buildings

Subject to Income Tax Article 4(2) which is final, in the amount of