This short presentation describes general feature of PSC (conventional cost recovery and gross split), pretax split and post tax split, tax treaty in general, specific issues on PPh ps 26(4) in PSC
Energy Transition and CO2 Emission Fact Sheet.pptxSampe Purba
This presentation reveals three important facts :
1. Big Countries to emit most of the CO2 from the past to present
2. The Energy mix for Electricity is dominated by Fossil based energy
3. Indonesia is one of the LOWEST CO2 emitter per capita in the world
Presentasi saya kali ini menjelaskan tentang bagaimana peran mekanisme berbasis pasar atau market based mechanism di dalam pencapaian target Indonesia dalam pengurangan emisi gas rumah kaca, terutama dengan mempertimbangkan biaya mitigasinya dengan mengambil pembelajaran dari implementasi CDM (Clean Development Mechanism) dan JCM (Joint Crediting Mechanism)..
Dalam bagian pertama saya jelaskan tentang bagaimana peta dari upaya pencapaian NDC (National Determined Contribution) atau target pengurangan emisi dari negara-negara di dunia. Dan selanjutnya saya menjelaskan tentang bagaimana peran mekanisme berbasis pasar di dalam pencapaian NDC.
Lebih lanjut juga saya sampaikan data implementasi dari mekanisme berbasis pasar yang telah diimplementasikan di Indonesia dan bagaimana kemudian integrasinya ke dalam implementasi NDC.
Yang kemudian memerlukan pembelajaran dan studi lebih mendalam adalah biaya mitigasi dari implementasi NDC sehingga negara dapat memilih mana yang kemudian harus dilakukan dan mana yang bisa dilepas ke pasar.
Contoh-contoh implementasi proyek pengurangan emisi secara riil akan dapat menjadi pembelajaran yang baik ke depan.
Jakarta, 4 September 2018
Energy Transition and CO2 Emission Fact Sheet.pptxSampe Purba
This presentation reveals three important facts :
1. Big Countries to emit most of the CO2 from the past to present
2. The Energy mix for Electricity is dominated by Fossil based energy
3. Indonesia is one of the LOWEST CO2 emitter per capita in the world
Presentasi saya kali ini menjelaskan tentang bagaimana peran mekanisme berbasis pasar atau market based mechanism di dalam pencapaian target Indonesia dalam pengurangan emisi gas rumah kaca, terutama dengan mempertimbangkan biaya mitigasinya dengan mengambil pembelajaran dari implementasi CDM (Clean Development Mechanism) dan JCM (Joint Crediting Mechanism)..
Dalam bagian pertama saya jelaskan tentang bagaimana peta dari upaya pencapaian NDC (National Determined Contribution) atau target pengurangan emisi dari negara-negara di dunia. Dan selanjutnya saya menjelaskan tentang bagaimana peran mekanisme berbasis pasar di dalam pencapaian NDC.
Lebih lanjut juga saya sampaikan data implementasi dari mekanisme berbasis pasar yang telah diimplementasikan di Indonesia dan bagaimana kemudian integrasinya ke dalam implementasi NDC.
Yang kemudian memerlukan pembelajaran dan studi lebih mendalam adalah biaya mitigasi dari implementasi NDC sehingga negara dapat memilih mana yang kemudian harus dilakukan dan mana yang bisa dilepas ke pasar.
Contoh-contoh implementasi proyek pengurangan emisi secara riil akan dapat menjadi pembelajaran yang baik ke depan.
Jakarta, 4 September 2018
Dian Lestari, BFK, Ministry of Finance - Green Finance Facility to Support Cl...OECD Environment
Presentation by Dian Lestari, BFK, Ministry of Finance - OECD Focus Group Discussion: Developing a green finance facility to catalyse private investment, 27 October 2020
Penerapan Konsep Kota Kompak pada Ibu Kota Negara Nusantara 030422 FINAL.pdfoswarmungkasa1
Kota Kompak menjadi salah satu prinsip pembangunan perkotaan yang diadopsi dalam pembangunan Ibu Kota Nusantara. bagaimana konsep dasarnya dan bagaimana IKN mengadopsi konsep ini menjadi menarik untuk disimak.
Pengelolaan dana REDD+: Indonesian Environment FundCIFOR-ICRAF
Presented by Endah Tri Kurniawaty, Environment Fund Management Agency (BPDLH), at "Science and Policy Dialogue III: How are benefits from REDD+ finance shared?", Jakarta-Indonesia, on 4 Aug 2022.
USU - Migas dalam konteks ketahanan energi nasional.pptxSampe Purba
Empat sub topik bahasan meliputi Geopolitik Energi, Ketahanan Energi dalam Perspektif Dinamika Global, Transisi Energi - Climate Change and geoeconomy issues, serta substansi arsitektur RUU Migas
Dian Lestari, BFK, Ministry of Finance - Green Finance Facility to Support Cl...OECD Environment
Presentation by Dian Lestari, BFK, Ministry of Finance - OECD Focus Group Discussion: Developing a green finance facility to catalyse private investment, 27 October 2020
Penerapan Konsep Kota Kompak pada Ibu Kota Negara Nusantara 030422 FINAL.pdfoswarmungkasa1
Kota Kompak menjadi salah satu prinsip pembangunan perkotaan yang diadopsi dalam pembangunan Ibu Kota Nusantara. bagaimana konsep dasarnya dan bagaimana IKN mengadopsi konsep ini menjadi menarik untuk disimak.
Pengelolaan dana REDD+: Indonesian Environment FundCIFOR-ICRAF
Presented by Endah Tri Kurniawaty, Environment Fund Management Agency (BPDLH), at "Science and Policy Dialogue III: How are benefits from REDD+ finance shared?", Jakarta-Indonesia, on 4 Aug 2022.
USU - Migas dalam konteks ketahanan energi nasional.pptxSampe Purba
Empat sub topik bahasan meliputi Geopolitik Energi, Ketahanan Energi dalam Perspektif Dinamika Global, Transisi Energi - Climate Change and geoeconomy issues, serta substansi arsitektur RUU Migas
Understanding GST in India: A Comprehensive Guidetaqwaaandtawheed
Welcome to the ultimate guide on Goods and Services Tax (GST) in India! 🌐
In this insightful presentation, we delve deep into the intricacies of India's GST system, demystifying the complexities and providing a clear understanding of its impact on businesses and consumers alike.
📊 Key Topics Covered:
Introduction to GST: Explore the fundamentals and the rationale behind the implementation of GST in India.
GST Structure: Uncover the structure of GST, including the different tax slabs and how they apply to various goods and services.
GST Registration and Compliance: Gain practical insights into the GST registration process and compliance requirements for businesses.
Impact on Businesses: Understand how GST has transformed the business landscape, affecting supply chains, pricing strategies, and overall financial management.
GST and Digital Transformation: Explore the role of technology in GST compliance and how businesses can leverage digital tools to streamline processes.
Common Challenges and Solutions: Address common challenges faced by businesses in adapting to GST and discover effective solutions.
GST and the Economy: Examine the broader economic implications of GST, including its role in promoting transparency and fostering economic growth.
🎓 Who Should Attend:
Business Owners and Entrepreneurs
Finance and Accounting Professionals
Students and Academia
Anyone curious about the impact of GST on the Indian economy
📈 Don't miss this opportunity to enhance your knowledge of GST and stay ahead in the ever-evolving business landscape. Join us on [Date and Time] to unlock the full potential of GST in India!
GST is one indirect tax for the whole nation, which will make India one unified common market.
GST is a single tax on the supply of goods and services, right from the manufacturer to the consumer. Credits of input taxes paid at each stage will be available in the subsequent stage of value addition, which makes GST essentially a tax only on value addition at each stage. The final consumer will thus bear only the GST charged by the last dealer in the supply chain, with set-off benefits at all the previous stages.
www.actouch.com
The Present Publication is the 57th Edition & Updated till Income-tax (20th Amendment) Rules, 2020 with the following noteworthy features:
·Taxmann’s series of Bestseller Books for more than Five
Decades
· Incorporates all the changes made till the Income-tax (20th
Amendment) Rules, 2020
· Follows the Six Sigma Approach to Achieve the Benchmark of
‘Zero Error’
· Coverage of this book includes:
o All Rules and Schemes, which are either notified under the Income-tax Act or are referred to in different provisions of the Income-tax Act, are covered
o Contains 23 divisions covering all Rules relevant under the Income-tax Act i.e.,
§ Income-tax Rules
§ ICDS
§ STT Rules
§ Equalisation Levy Rules
§ Small Saving Schemes, etc.
· All Forms Carry Action Points that explains the Relevant
Provisions and Process of Filing
· All Redundant and e-Forms are Marked for Quick
Identifications
Similar to Tax treaty Application on PSC Contracts.pptx (20)
IPO of Oil and Gas SOE - Business Risk and Governance.pdfSampe Purba
This short presentation describes the benefit and concern over the Initial Public Offering of Oil and Gas State owned enterprises.
The very concern is to harmonize between the Good Corporate Governance (internal regulation) and Business Judgment Rules (external concern) where many Law Enforcement Officers sometimes not consider both in balance
Energy - Geostrategy and Geoeconomy - UNHAN - public.pptxSampe Purba
Collaborative and inclusiveness and fairness are the key to attack Climate Change
DS 592 dispute on NICKEL ... seems we still need long way journey for justice.
Energy Disruption - Electricity - Emission.pptxSampe Purba
This presentation displays that Indonesia is the LOWEST CO2 per Capita emission in the world.
We should aware an implication of a continuing conflict of Russia and NATO in Ukraine with respect to energy security
Non Dollar Currency and Non LIBOR Interest in.pptxSampe Purba
This presentation describes the history of the long US based Dollar and England based interest rate LIBOR - established up to the post world war II, being challenged by the new emerging powerful Natural Resources Based Economy such as Russia and club of BRICS. The dependency of European Union to Russian Gas is a test case, whether this long established financial and monetary order can be dethroned
IBU KOTA NUSANTARA sebagai Center of Gravity-1.pptxSampe Purba
Presentasi singkat ini mengcapture isue isue terkaut dengan pemindahan ibu kota suatu negara. Ibu kota adalah Center of Gravity, yang memiliki dimensi Kesejahteraan, Pertahanan, Iptek dan Hukum.
Pemindahan ibu kota bukan sekedar pemindahan orang dan infrastruktur.
This presentation discuss on the role and responsibility of global community in order to accelerate the achievement of decarbonization through a smooth, just and equitable transition
This short presentation discussing the Bureaucracy concept to fulfill its public service - in the era of post covid 19, from the perspective of moving from VUCA to BANI Concept, when responding from uncertain dynamics to an incomprehensible environment
Geopolitics and Payment System - a challenge to US dollar domination .pptxSampe Purba
This presentation discusses the historical perspective of world peace and security order post World war II, the rise of US dollar as International payment instruments and challenge to its domination - triggered by Russia - NATO Conflict.
As the concluding remarks are :
1. Geopolitics – Geostrategy – Geo economy are dynamics
2. New Equilibrium in Global Politics and Economy Power Sharing, might shock the global order temporarily
3. Money is the blood of modern global economy. You control the money circulation, meaning you already control more than half of the POWER
4. While Pact sunt servanda is the credo of Civic Society, at the end of a day it is the NATIONAL INTEREST to govern the State Political Behaviour
Energy : Geopolitics - Geostrategy - Geoeconomy, Lesson learned from Russia -...Sampe Purba
This presentation describes how in terms of geoeconomics, capitalizing the political and economy geography can be utilize as a bargain position to pursue geopolitical objectives
Cop26 Rowing between global and national interestSampe Purba
This presentation discloses how the countries behave and react towards the climate change. While all agrees that climate change is a serious issues, but when it comes to reality, all countries do look inward and into its own interest.
Logam tanah jarang rare earth a strategic critical mineral Sampe Purba
this presentation discovers that rare earth - is a very important component to support sophisticated products and renewable energy products. Yet, we find an anomaly, as most of the reserves and products are controlled by PRC countries, while the other G 7 countries not eager to discover and develop more. Indonesia has an abundance potential of rare earth resources yet to materialize
Green economy - Green Energy - Energy transition Sampe Purba
1. Developed countries should bear the burden balanced with the environmental impact of the manufacturing industry emitting carbon significantly, and from electricity consumed massively
Carbon trading as an instrument that offsets emissions, in essence, only transfers the calculation of the surplus minus the carbon balance
2. Developed countries should understand that in developing countries like Indonesia, the existing electricity generation system is very significant using coal-based fuels.
3. Access to finance, market restrictions and product embargoes and green certificates imposed by developed countries should be based on the achievement of NDCs in each country.
Towards cleaner energy - a collaborative world effortsSampe Purba
Presented in 3rd Asian Pollution Control and Sustainable Energy, May 2021
The bottom line of the messages are : Commitment to cleaner energy should be a real one, by taking into account each country's specific circumstances. One who polluted more, should take more responsibility. Carbon trading mechanism is somewhat more like a tactical trap by polluter producers and huge energy consumers at the expense of conserving O2 countries. This kind of platform may lead to vicious circle of atmosphere pollution
The contents : National Energy Grand Strategy, National General Energy Plan, Oil and Gas Reserves and Projects, Gas Infrastructures, The role of gas in National Economy, LNG Projection, Conversion of Crude to Gas as fuel in electricity powerplant
Transition from coal fire power generation to renewable energy for public.pptxSampe Purba
the global and national fact sheet shows, despite the campaign to renewable energy, the dependence on fossil based energy is the reality. Every country needs to make a comprehensive assessment in line to its national interest, without leaving the responsibility as global citizen sharing the same universe.
Turin Startup Ecosystem 2024 - Ricerca sulle Startup e il Sistema dell'Innov...Quotidiano Piemontese
Turin Startup Ecosystem 2024
Una ricerca de il Club degli Investitori, in collaborazione con ToTeM Torino Tech Map e con il supporto della ESCP Business School e di Growth Capital
when will pi network coin be available on crypto exchange.DOT TECH
There is no set date for when Pi coins will enter the market.
However, the developers are working hard to get them released as soon as possible.
Once they are available, users will be able to exchange other cryptocurrencies for Pi coins on designated exchanges.
But for now the only way to sell your pi coins is through verified pi vendor.
Here is the telegram contact of my personal pi vendor
@Pi_vendor_247
how to sell pi coins in all Africa Countries.DOT TECH
Yes. You can sell your pi network for other cryptocurrencies like Bitcoin, usdt , Ethereum and other currencies And this is done easily with the help from a pi merchant.
What is a pi merchant ?
Since pi is not launched yet in any exchange. The only way you can sell right now is through merchants.
A verified Pi merchant is someone who buys pi network coins from miners and resell them to investors looking forward to hold massive quantities of pi coins before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
If you are looking for a pi coin investor. Then look no further because I have the right one he is a pi vendor (he buy and resell to whales in China). I met him on a crypto conference and ever since I and my friends have sold more than 10k pi coins to him And he bought all and still want more. I will drop his telegram handle below just send him a message.
@Pi_vendor_247
USDA Loans in California: A Comprehensive Overview.pptxmarketing367770
USDA Loans in California: A Comprehensive Overview
If you're dreaming of owning a home in California's rural or suburban areas, a USDA loan might be the perfect solution. The U.S. Department of Agriculture (USDA) offers these loans to help low-to-moderate-income individuals and families achieve homeownership.
Key Features of USDA Loans:
Zero Down Payment: USDA loans require no down payment, making homeownership more accessible.
Competitive Interest Rates: These loans often come with lower interest rates compared to conventional loans.
Flexible Credit Requirements: USDA loans have more lenient credit score requirements, helping those with less-than-perfect credit.
Guaranteed Loan Program: The USDA guarantees a portion of the loan, reducing risk for lenders and expanding borrowing options.
Eligibility Criteria:
Location: The property must be located in a USDA-designated rural or suburban area. Many areas in California qualify.
Income Limits: Applicants must meet income guidelines, which vary by region and household size.
Primary Residence: The home must be used as the borrower's primary residence.
Application Process:
Find a USDA-Approved Lender: Not all lenders offer USDA loans, so it's essential to choose one approved by the USDA.
Pre-Qualification: Determine your eligibility and the amount you can borrow.
Property Search: Look for properties in eligible rural or suburban areas.
Loan Application: Submit your application, including financial and personal information.
Processing and Approval: The lender and USDA will review your application. If approved, you can proceed to closing.
USDA loans are an excellent option for those looking to buy a home in California's rural and suburban areas. With no down payment and flexible requirements, these loans make homeownership more attainable for many families. Explore your eligibility today and take the first step toward owning your dream home.
how can i use my minded pi coins I need some funds.DOT TECH
If you are interested in selling your pi coins, i have a verified pi merchant, who buys pi coins and resell them to exchanges looking forward to hold till mainnet launch.
Because the core team has announced that pi network will not be doing any pre-sale. The only way exchanges like huobi, bitmart and hotbit can get pi is by buying from miners.
Now a merchant stands in between these exchanges and the miners. As a link to make transactions smooth. Because right now in the enclosed mainnet you can't sell pi coins your self. You need the help of a merchant,
i will leave the telegram contact of my personal pi merchant below. 👇 I and my friends has traded more than 3000pi coins with him successfully.
@Pi_vendor_247
how can I sell pi coins after successfully completing KYCDOT TECH
Pi coins is not launched yet in any exchange 💱 this means it's not swappable, the current pi displaying on coin market cap is the iou version of pi. And you can learn all about that on my previous post.
RIGHT NOW THE ONLY WAY you can sell pi coins is through verified pi merchants. A pi merchant is someone who buys pi coins and resell them to exchanges and crypto whales. Looking forward to hold massive quantities of pi coins before the mainnet launch.
This is because pi network is not doing any pre-sale or ico offerings, the only way to get my coins is from buying from miners. So a merchant facilitates the transactions between the miners and these exchanges holding pi.
I and my friends has sold more than 6000 pi coins successfully with this method. I will be happy to share the contact of my personal pi merchant. The one i trade with, if you have your own merchant you can trade with them. For those who are new.
Message: @Pi_vendor_247 on telegram.
I wouldn't advise you selling all percentage of the pi coins. Leave at least a before so its a win win during open mainnet. Have a nice day pioneers ♥️
#kyc #mainnet #picoins #pi #sellpi #piwallet
#pinetwork
Currently pi network is not tradable on binance or any other exchange because we are still in the enclosed mainnet.
Right now the only way to sell pi coins is by trading with a verified merchant.
What is a pi merchant?
A pi merchant is someone verified by pi network team and allowed to barter pi coins for goods and services.
Since pi network is not doing any pre-sale The only way exchanges like binance/huobi or crypto whales can get pi is by buying from miners. And a merchant stands in between the exchanges and the miners.
I will leave the telegram contact of my personal pi merchant. I and my friends has traded more than 6000pi coins successfully
Tele-gram
@Pi_vendor_247
how to swap pi coins to foreign currency withdrawable.DOT TECH
As of my last update, Pi is still in the testing phase and is not tradable on any exchanges.
However, Pi Network has announced plans to launch its Testnet and Mainnet in the future, which may include listing Pi on exchanges.
The current method for selling pi coins involves exchanging them with a pi vendor who purchases pi coins for investment reasons.
If you want to sell your pi coins, reach out to a pi vendor and sell them to anyone looking to sell pi coins from any country around the globe.
Below is the contact information for my personal pi vendor.
Telegram: @Pi_vendor_247
how to sell pi coins in South Korea profitably.DOT TECH
Yes. You can sell your pi network coins in South Korea or any other country, by finding a verified pi merchant
What is a verified pi merchant?
Since pi network is not launched yet on any exchange, the only way you can sell pi coins is by selling to a verified pi merchant, and this is because pi network is not launched yet on any exchange and no pre-sale or ico offerings Is done on pi.
Since there is no pre-sale, the only way exchanges can get pi is by buying from miners. So a pi merchant facilitates these transactions by acting as a bridge for both transactions.
How can i find a pi vendor/merchant?
Well for those who haven't traded with a pi merchant or who don't already have one. I will leave the telegram id of my personal pi merchant who i trade pi with.
Tele gram: @Pi_vendor_247
#pi #sell #nigeria #pinetwork #picoins #sellpi #Nigerian #tradepi #pinetworkcoins #sellmypi
Financial Assets: Debit vs Equity Securities.pptxWrito-Finance
financial assets represent claim for future benefit or cash. Financial assets are formed by establishing contracts between participants. These financial assets are used for collection of huge amounts of money for business purposes.
Two major Types: Debt Securities and Equity Securities.
Debt Securities are Also known as fixed-income securities or instruments. The type of assets is formed by establishing contracts between investor and issuer of the asset.
• The first type of Debit securities is BONDS. Bonds are issued by corporations and government (both local and national government).
• The second important type of Debit security is NOTES. Apart from similarities associated with notes and bonds, notes have shorter term maturity.
• The 3rd important type of Debit security is TRESURY BILLS. These securities have short-term ranging from three months, six months, and one year. Issuer of such securities are governments.
• Above discussed debit securities are mostly issued by governments and corporations. CERTIFICATE OF DEPOSITS CDs are issued by Banks and Financial Institutions. Risk factor associated with CDs gets reduced when issued by reputable institutions or Banks.
Following are the risk attached with debt securities: Credit risk, interest rate risk and currency risk
There are no fixed maturity dates in such securities, and asset’s value is determined by company’s performance. There are two major types of equity securities: common stock and preferred stock.
Common Stock: These are simple equity securities and bear no complexities which the preferred stock bears. Holders of such securities or instrument have the voting rights when it comes to select the company’s board of director or the business decisions to be made.
Preferred Stock: Preferred stocks are sometime referred to as hybrid securities, because it contains elements of both debit security and equity security. Preferred stock confers ownership rights to security holder that is why it is equity instrument
<a href="https://www.writofinance.com/equity-securities-features-types-risk/" >Equity securities </a> as a whole is used for capital funding for companies. Companies have multiple expenses to cover. Potential growth of company is required in competitive market. So, these securities are used for capital generation, and then uses it for company’s growth.
Concluding remarks
Both are employed in business. Businesses are often established through debit securities, then what is the need for equity securities. Companies have to cover multiple expenses and expansion of business. They can also use equity instruments for repayment of debits. So, there are multiple uses for securities. As an investor, you need tools for analysis. Investment decisions are made by carefully analyzing the market. For better analysis of the stock market, investors often employ financial analysis of companies.
how to sell pi coins on Bitmart crypto exchangeDOT TECH
Yes. Pi network coins can be exchanged but not on bitmart exchange. Because pi network is still in the enclosed mainnet. The only way pioneers are able to trade pi coins is by reselling the pi coins to pi verified merchants.
A verified merchant is someone who buys pi network coins and resell it to exchanges looking forward to hold till mainnet launch.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
The Evolution of Non-Banking Financial Companies (NBFCs) in India: Challenges...beulahfernandes8
Role in Financial System
NBFCs are critical in bridging the financial inclusion gap.
They provide specialized financial services that cater to segments often neglected by traditional banks.
Economic Impact
NBFCs contribute significantly to India's GDP.
They support sectors like micro, small, and medium enterprises (MSMEs), housing finance, and personal loans.
what is the best method to sell pi coins in 2024DOT TECH
The best way to sell your pi coins safely is trading with an exchange..but since pi is not launched in any exchange, and second option is through a VERIFIED pi merchant.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and pioneers and resell them to Investors looking forward to hold massive amounts before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade pi coins with.
@Pi_vendor_247
What website can I sell pi coins securely.DOT TECH
Currently there are no website or exchange that allow buying or selling of pi coins..
But you can still easily sell pi coins, by reselling it to exchanges/crypto whales interested in holding thousands of pi coins before the mainnet launch.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and resell to these crypto whales and holders of pi..
This is because pi network is not doing any pre-sale. The only way exchanges can get pi is by buying from miners and pi merchants stands in between the miners and the exchanges.
How can I sell my pi coins?
Selling pi coins is really easy, but first you need to migrate to mainnet wallet before you can do that. I will leave the telegram contact of my personal pi merchant to trade with.
Tele-gram.
@Pi_vendor_247
6. Tax Treaty
Bilateral International Agreement by the Government to resolve issues
related to avoidance of double taxation and to prevent tax evasion
with respect to taxes of income art. 32A UU PPh
To rules right to tax on income received by the residents of one or both
countries on active and passive income
Normally it applies of Permanent Establishment – a fixed place of
business through which the business of an enterprise is wholly or partly
carried on Ps 26(4) Income Tax
Structures, models and scopes varies (i.e OECD model, UN Models etc
Content of typical tax treaty provisions : Personal connecting factors
(residence concept), Objectives (source), Administration procedures,
Rules to govern the entry in to force and termination
6
8. Depending on the Contract in some cases, Parties
entitle to tax treaty shall refunds to BPMIGAS
8
9. IN case Percentage based on Prevailing Income tax
[not nail down], Percentage adjusted
9
10. ISSUES – Specific to PSC Contracts
1. Apakah Persyaratan Subjektif dan Objektif yang harus
dipenuhi oleh Interest holder (s) agar dapat
menerapkan ketentuan Tax Treaty
2. Dalam hal ketentuan 15.4.2 apply (Interest holders
entitle utk menerapkan tax treaty] namun harus
menyetor Kembali kekurangannya ke BPMIGAS/
SKKMigas, bagaimana Pengaturan dan Prosedurnya
3. Dalam hal ada dispute mengenai pemahaman dan
penerapan Tax treaty tersebut, bagaimana mekanisme
penyelesaiannya
4. Cases
10
11. 11
CONCESSION
CONTRACT
OF WORK
PSC
UU No. 8/1971
COOPERATION
CONTRACT
UU No. 22/2001
PERKEMBANGAN SISTEM KONTRAK INDONESIA
1960 1966 2001 Now
UU - Indische Mijnwet, Staatsblad th.1899 No.214
UU No.44 Prp/1960
UU No.8/1971
Permen No. 22 / 2008
PP No. 35 / 2004*
UU No. 22 / 2001
<
1960
1960
-
1966
1966
-
2001
2001
-
now
PP No. 42 / 2002
PP No. 35 / 1994
PP No. 79 / 2010
*)Telah beberapa kali diubah dengan PP 34/2005 dan PP 55/2009
PP No. 27 / 2017
PP No. 53 / 2018
12. 12
PRODUCTION SHARING CONTRACTS
1964 1978 1988 1988 1989 1992 1994
PSC Gen. 1
• CR < 40%
• Tax paid by NOC
• DMO = max 25% & US$ 0,2
• Commercial Interest offered
to NOC
PSC Gen. 2
• CR = 100%
• Tax by Contractor = 56%
• DMO Holiday = 5 yr
• IC = 20%
PSC Gen. 3
• Tax = 48%
• Oil Split 85:15
• Gas Split 70:30
Paket Insetif 1
• IC tanpa syarat
• Commercial, min 25%
• DMO = 10% x Price
• FTP = 20%
• Frontier Split:
<50 MBOPD =80:20
50 -150 MBOPD =85:15
>150 MBOPD =90:10
Paket Insentif 2
• EOR & Marginal
80:20 (konv.)
75:25 (Frontier)
• IC Deep Sea
10% (oil)
55% (gas)
Paket Insetif 3
• IC Pra-tersier= 110%
• IC Deep Sea =125%
• DMO = 15% x Price
• Gas Split
Konv.65:35 & Frontier 60:40
DeepSea 60:40 (old) & DeepSea 55:45 (new)
• Oil Split
Frontier 80:20 & Deep Sea 80:20
Paket Insentif 4
• Frontier
Oil Split 55:45
Gas Split 60:40
• DMO = 25% x Price
• FTP = 15%
• Kewajiban ASR