Emerging Markets Rates and Currencies Handbook

29 Citi | Emerging Markets Currencies Handbook 2021 Indonesia Item Inter-Co Debt Offshore Bank Loans Offshore Local Borrowing Derivatives Equity W/H Tax 20% WHT or lower (subject to implementing regulation) Under certain tax treaties typically 10%, with further reduction possible on country-by- country basis 20% WHT or lower (subject to implementing regulation) • Under certain tax treaties typically 10%, with further reduction possible on country-by- country basis • Exempt for certain countries if paid to a bank but linked to a government loan agreement or paid to specific financial institutions/banks Interest paid to a resident company is subject to 15% WHT, which is creditable for the receiving company N/A Dividends paid from a resident sub to non- resident parent: 20% WHT, unless treaty in place then typically 10-15% Dividends paid from a resident to a individual tax payer is 0% provided such dividend is invested in Indonesia for a certain period of time (subject to implementing regulation) Dividends paid from a resident to corporate tax payer is 0% (without any condition) Deductibility of interests Generally deductible, unless D/E > 4x (excluding certain industries) • FI’s and Infrastructure = not applicable • Mining and Oil & Gas industries carry special rules Transfer pricing rules apply N/A N/A Deductibility of FX losses FX losses are considered as Deductible expense while an FX gain is considered as taxable income, with the requirement FX recognition applied consistently Other taxes, duties Stamp duty is nominal and payable as a fixed amount N/A N/A Comments N/A N/A N/A N/A N/A Note: Citigroup Inc. and any of its affiliates do not provide accounting, tax, or legal advice. Please seek advice from a relevant licensed advisor. Source: Relevant legislation, publicly available sources. Subsidiary Funding — Tax Consideration Tax Summary — Indonesia