This agreement establishes a framework for avoiding double taxation and preventing tax evasion between Indonesia and South Korea with respect to income taxes. It covers the taxes imposed by each country that are subject to this agreement. It defines terms like "resident", "permanent establishment", and outlines rules for determining residency for individuals and companies for tax purposes. The agreement also specifies what level of business activity or property ownership in one country creates a taxable presence that may be taxed by that country.
Singapore India DTA Incorporating Protocol 2005Maverick Tan
This document summarizes an agreement between the governments of Singapore and India to avoid double taxation and prevent tax evasion with respect to income taxes. It was signed on January 24, 1994 and took effect on January 1, 1994 for Singapore and April 1, 1994 for India. The agreement defines key terms and outlines how residence and permanent establishments are determined for tax purposes. It also describes the taxes covered under the agreement.
This document is a double taxation agreement between the UK and Bangladesh signed in 1979. Some key points:
- It aims to avoid double taxation and prevent fiscal evasion on taxes on income and capital gains.
- It covers UK taxes like income tax, corporation tax, and capital gains tax, and Bangladesh taxes like income tax and super tax.
- It defines terms like "resident of a Contracting State" and "permanent establishment" and outlines how income from different sources like business profits, dividends, interest, and royalties will be taxed.
- It includes provisions for eliminating double taxation and procedures for resolving disputes between the two countries.
This document is an agreement between Indonesia and Singapore to avoid double taxation and prevent tax evasion on income taxes. It outlines the personal and tax coverage of the agreement. Key provisions include:
- Applying to individuals and companies resident in either country.
- Covering income taxes imposed in each country, including taxes on gains, wages, and elements of income.
- Defining the existing taxes covered in each country.
- Allowing amendments if tax laws change significantly in either country.
This document summarizes the key points of the Double Taxation Agreement between India and Bangladesh signed on May 27, 1992. It aims to avoid double taxation and prevent fiscal evasion with respect to taxes on income for the two countries. The agreement applies to individuals and companies that are residents of India or Bangladesh. It specifies the taxes covered in each country and defines terms like "resident", "permanent establishment", and assigns authority to the respective revenue boards of each country.
This document outlines the Financial Institutions Ordinance of 2001 in Pakistan. The ordinance aims to repeal and re-enact the Banking Companies (Recovery of Loans, Advances, Credits and Finances) Act of 1997 with some modifications. It establishes Banking Courts to handle cases related to recovery of finances extended by financial institutions in a timely manner. The ordinance defines key terms, outlines the duties of customers to fulfill obligations, and sets out procedures for financial institutions to recover written-off finances expeditiously through the new Banking Courts.
recently there ismeaure amendments in the Specific Relief Act and the public infrastruture projects are given preference as due to injunctions there was delay in public projects causing huge loss the public exchequer.
The document discusses regulations around insider trading and price sensitive information in Bangladesh. It defines price sensitive information and insider trading, and prohibits the latter. The Securities and Exchange Commission is responsible for regulating the capital market and protecting investors. It can investigate companies, inspect records, audit intermediaries, and prohibit fraudulent practices. The document also discusses prospectuses, listing and delisting of companies, restrictions on securities dealings, and information that must be included in directors' reports. Insider trading is prohibited, and insiders are defined as those who possess non-public material information.
Companies incorporation regulations 2017 in PakistanOLY Consultant
The document is a notification from the Government of Pakistan Securities and Exchange Commission regarding new Companies (Incorporation) Regulations, 2017. Some key points:
- The regulations provide rules for reserving a company name and incorporating a company, allowing for separate or combined applications.
- Certain words are prohibited from use in company names without meeting specific criteria, such as those associated with governments, political figures, courts, banks, armed forces, etc.
- Other restricted words can only be used if criteria are met, for example "association" requires a license from the Commission, and "bank" requires approval from the State Bank of Pakistan.
- The regulations lay out the process for applying to reserve a name
Singapore India DTA Incorporating Protocol 2005Maverick Tan
This document summarizes an agreement between the governments of Singapore and India to avoid double taxation and prevent tax evasion with respect to income taxes. It was signed on January 24, 1994 and took effect on January 1, 1994 for Singapore and April 1, 1994 for India. The agreement defines key terms and outlines how residence and permanent establishments are determined for tax purposes. It also describes the taxes covered under the agreement.
This document is a double taxation agreement between the UK and Bangladesh signed in 1979. Some key points:
- It aims to avoid double taxation and prevent fiscal evasion on taxes on income and capital gains.
- It covers UK taxes like income tax, corporation tax, and capital gains tax, and Bangladesh taxes like income tax and super tax.
- It defines terms like "resident of a Contracting State" and "permanent establishment" and outlines how income from different sources like business profits, dividends, interest, and royalties will be taxed.
- It includes provisions for eliminating double taxation and procedures for resolving disputes between the two countries.
This document is an agreement between Indonesia and Singapore to avoid double taxation and prevent tax evasion on income taxes. It outlines the personal and tax coverage of the agreement. Key provisions include:
- Applying to individuals and companies resident in either country.
- Covering income taxes imposed in each country, including taxes on gains, wages, and elements of income.
- Defining the existing taxes covered in each country.
- Allowing amendments if tax laws change significantly in either country.
This document summarizes the key points of the Double Taxation Agreement between India and Bangladesh signed on May 27, 1992. It aims to avoid double taxation and prevent fiscal evasion with respect to taxes on income for the two countries. The agreement applies to individuals and companies that are residents of India or Bangladesh. It specifies the taxes covered in each country and defines terms like "resident", "permanent establishment", and assigns authority to the respective revenue boards of each country.
This document outlines the Financial Institutions Ordinance of 2001 in Pakistan. The ordinance aims to repeal and re-enact the Banking Companies (Recovery of Loans, Advances, Credits and Finances) Act of 1997 with some modifications. It establishes Banking Courts to handle cases related to recovery of finances extended by financial institutions in a timely manner. The ordinance defines key terms, outlines the duties of customers to fulfill obligations, and sets out procedures for financial institutions to recover written-off finances expeditiously through the new Banking Courts.
recently there ismeaure amendments in the Specific Relief Act and the public infrastruture projects are given preference as due to injunctions there was delay in public projects causing huge loss the public exchequer.
The document discusses regulations around insider trading and price sensitive information in Bangladesh. It defines price sensitive information and insider trading, and prohibits the latter. The Securities and Exchange Commission is responsible for regulating the capital market and protecting investors. It can investigate companies, inspect records, audit intermediaries, and prohibit fraudulent practices. The document also discusses prospectuses, listing and delisting of companies, restrictions on securities dealings, and information that must be included in directors' reports. Insider trading is prohibited, and insiders are defined as those who possess non-public material information.
Companies incorporation regulations 2017 in PakistanOLY Consultant
The document is a notification from the Government of Pakistan Securities and Exchange Commission regarding new Companies (Incorporation) Regulations, 2017. Some key points:
- The regulations provide rules for reserving a company name and incorporating a company, allowing for separate or combined applications.
- Certain words are prohibited from use in company names without meeting specific criteria, such as those associated with governments, political figures, courts, banks, armed forces, etc.
- Other restricted words can only be used if criteria are met, for example "association" requires a license from the Commission, and "bank" requires approval from the State Bank of Pakistan.
- The regulations lay out the process for applying to reserve a name
The Specific Relief of Act 1877
The Law of Limitation Act, 1908
ARNAB KUMAR DAS
Port City International University,
Chittagong, Bangladesh.
SID: LLB 00305037
The Specific Relief of Act 1877
The Law of Limitation Act, 1908
ARNAB KUMAR DAS
Port City International University,
Chittagong, Bangladesh.
SID: LLB 00305037
This document provides an overview of the Specific Relief Act of 1963 in India. Some key points:
- The Act defines and amends laws related to specific types of relief. It extends to all of India except Jammu and Kashmir.
- The Act covers recovering possession of property, specific performance of contracts, and outlines which contracts can and cannot be specifically enforced.
- It establishes that specific relief can only be granted to enforce individual civil rights, not penal laws. Specific performance of contracts depends on factors like whether compensation is adequate and whether the court can supervise performance.
- The Act specifies who can obtain specific performance, such as parties to a contract or their representatives, and limits it in some
1. Short title, extent and commencement.—(1) This Act may be called the Specific Relief Act, 1963.
(2) It extends to the whole of India except the State of Jammu and Kashmir.
(3) It shall come into force on such date 1 as the Central Government may, by notification in the Official Gazette, appoint.
This document appears to be part of an act from Bangladesh related to specific relief. It begins with a preamble stating it is to define and amend the law relating to certain kinds of specific relief obtainable in civil suits. It then provides definitions for terms used in the act like obligation, trust, and trustee. The act discusses different types of specific relief that can be granted, including taking possession of property, ordering a party to perform an act, and preventing a party from acting. It provides guidance on recovering possession of both immovable and movable property and on the specific performance of contracts.
he Specific Relief Act, 1963 is an Act of the Parliament of India which provides remedies for persons whose civil or contractual rights have been violated. It replaced an earlier Act of 1877. The following kinds of remedies may be granted by a court under the provisions of the Specific Relief Act:
Recovery of possession of property
Specific performance of contracts
Rectification of instruments
Rescission of contracts
Cancellation of Instruments
Declaratory decrees
Injunction
This document provides the definitions and preliminary information for the Code of Civil Procedure, 1908 in Bangladesh. It defines key terms used in the code such as "decree", "judgment", "pleader", and "public officer". It also outlines some general principles for Bangladeshi civil procedure such as which courts have jurisdiction over which types of suits, the concept of res judicata, and where suits should be instituted based on the location of the subject matter in dispute.
The document is an excerpt from the Limitation Act, 1908 of Bangladesh. It discusses provisions related to computing periods of limitation for filing lawsuits, appeals or applications. Some key points:
- It excludes time during which the defendant was absent from Bangladesh or certain other territories.
- It excludes time during which the plaintiff was prosecuting another case in good faith against the same defendant but the court lacked jurisdiction.
- It excludes time during which a proceeding was stayed by an injunction or order, and the time for which any notice was given according to law.
- Special provisions apply if the right to sue accrued but the person with the right or the potential defendant died before the right accrued or the case
This document is the preamble and introductory chapter of the Penal Code of Bangladesh from 1860. It establishes the title and extent of operation for the Penal Code, noting that it shall take effect throughout Bangladesh. It also establishes that individuals shall be liable under this Code for offenses committed within Bangladesh, and that some provisions extend extraterritorial application for offenses committed by Bangladeshi citizens or on ships/aircraft registered in Bangladesh wherever located. Finally, it provides initial definitions for terms that are used throughout the Code, such as "public servant", "wrongful gain/loss", and "document".
Liability Insurance is available to protect you against liability arising out of any accident affecting any person(s) occurring while handling hazardous substances. Came into force on 01st April 1991
AMENDMENTS TO SARFAESI ACT/RULES/DRT ACT AND RULES WHICH HAVE BEEN ENFORCEDMukesh Chand
The document summarizes key amendments to the Security Interest (Enforcement) Rules, 2002 and the Debt Recovery Tribunal (Procedure) Rules, 1993 in India that came into effect from November 4, 2016. Some of the major changes include:
1) Allowing delivery of notices by hand delivery in addition to other modes.
2) Reducing the notice period for subsequent auctions of secured assets from 30 days to 15 days.
3) Allowing service of notices via email in addition to other modes.
4) Providing for public auctions, including e-auctions of secured assets.
5) Reducing timelines for filing written statements and replies in DRT recovery applications.
This is a special Act.Though it has less sections but all are very effective. The Court can see this Act as guidance to use its discretion in judicious manner.
This document provides an overview of specific relief under Indian law. It discusses key concepts like specific performance of contracts and recovery of possession of property. Specific relief refers to a form of judicial remedy where a party is compelled by a civil court to do or refrain from doing a certain act. The Specific Relief Act of 1877 governs specific relief in India and is based on principles of equity. It allows for specific performance of contracts for sale of immovable property, partial performance of contracts where part of the obligation cannot be fulfilled, and rights of purchasers against vendors with imperfect title. Certain types of contracts cannot be specifically enforced, such as those requiring continuous performance over 3 years or those with uncertain terms.
The document provides an overview of benami transactions and the Benami Transactions (Prohibition) Act 1988 in India. Some key points:
- Benami means "property without name" and refers to transactions where property is purchased in someone else's name without intending to benefit them.
- The 1988 Act was introduced to prohibit benami transactions and recover properties held benami, as such transactions were previously abused to evade taxes, circumvent land ceilings, and commit fraud.
- Under the Act, benami transactions are prohibited and no suits can be filed to claim rights over benami properties. Benami properties are also liable for acquisition by authorities. However, the Act had deficiencies in implementation and scope
The Reserve Bank of India regulates the establishment of branches, liaison offices, or other places of business in India by foreign companies. No foreign company can set up such an office without RBI approval, except for banking and insurance companies regulated by other acts. Foreign companies can also set up standalone branches in Special Economic Zones to conduct permitted business activities without RBI approval if they meet certain conditions. The regulations specify the application process and permitted activities of foreign branches and liaison offices in India.
The document summarizes key aspects of the Benami Transactions (Prohibition) Amendment Act 2016 in India. It defines benami transactions as purchasing or holding property in someone else's name while providing the consideration. The Act aims to prohibit benami transactions and allow for confiscation of benami properties. It establishes authorities like initiating officers, adjudicating authorities, and an appellate tribunal to oversee the attachment, adjudication and confiscation of benami properties. Penalties for offenses include fines up to 25% of fair market value and imprisonment from 1-7 years. The Act is expected to impact the real estate market by reducing black money transactions and property disputes.
Conditional Sale and Purchase Agreement / Contract (Purchase this doc, Text: ...GLC
This document outlines a conditional sale and purchase agreement between multiple parties for shares in a company. Key points:
- The sellers agree to sell their shares in the company to the purchaser, subject to certain terms and conditions being met.
- The purchase price for the shares is specified for each seller. Payment is due within 3 months of signing the agreement.
- Several conditions must be fulfilled before and after payment, including obtaining necessary approvals.
- Failure to meet the conditions or make payment on time results in default consequences like termination of the agreement or repayment of funds.
- Disputes will be resolved via arbitration in Indonesia and governed by Indonesian law. The parties agree not to pursue matters
The document provides an overview of the Specific Relief Act 1963 in India. It discusses:
1) The Act defines and amends the law relating to specific relief for enforcing civil rights. It does not apply to penal rights.
2) The Act provides for seven types of specific relief: recovery of possession of property, specific performance of contracts, rectification of instruments, rescission of contracts, cancellation of instruments, declaratory decrees, and preventive relief.
3) Specific performance of contracts can be granted for immovable property transactions but generally not for movable property where compensation is adequate.
The document discusses benami transactions under Indian law. It defines key terms like benamidar and beneficial owner. It summarizes the Benami Transactions (Prohibition) Act of 1988 and the 2011 bill that replaced it. The bill prohibits benami transactions and makes property involved liable for confiscation. It imposes penalties for engaging in benami transactions or providing false information regarding such transactions.
This document is the Evidence Act of 1872 from Bangladesh. It defines key terms used in evidence and testimony such as "court", "fact", "document", and "evidence". It also outlines the relevance of different types of facts that can be presented as evidence, such as facts that are part of the same transaction, facts that provide motive or context, and facts that are necessary to explain other facts in the case. The document establishes the framework for how evidence is treated and presented in legal proceedings in Bangladeshi courts.
CONVENTIONBETWEENTHE ROYAL GOVERNMENT OF THAILANDANDTHE GOVERNMENT.docxmaxinesmith73660
This document outlines a convention between Thailand and Singapore to avoid double taxation and prevent tax evasion on income. It details that the governments desire to conclude an agreement (Article 1), the taxes covered which include income taxes (Article 2), definitions of terms like resident and permanent establishment (Articles 3-5), and how to tax different types of income including business profits, shipping/air transport, associated enterprises, dividends, and interest (Articles 6-11). The purpose is to establish a framework for taxing income of residents in one or both countries in order to eliminate double taxation.
This document is a convention between Moldova and Bosnia and Herzegovina to avoid double taxation and prevent tax evasion on income and property taxes. It outlines how income earned in one country by residents of the other will be taxed. It defines terms like resident, permanent establishment, and outlines which specific taxes are covered. It also provides rules for taxing business profits, international transportation income, property income, and dividends between the two countries.
The Specific Relief of Act 1877
The Law of Limitation Act, 1908
ARNAB KUMAR DAS
Port City International University,
Chittagong, Bangladesh.
SID: LLB 00305037
The Specific Relief of Act 1877
The Law of Limitation Act, 1908
ARNAB KUMAR DAS
Port City International University,
Chittagong, Bangladesh.
SID: LLB 00305037
This document provides an overview of the Specific Relief Act of 1963 in India. Some key points:
- The Act defines and amends laws related to specific types of relief. It extends to all of India except Jammu and Kashmir.
- The Act covers recovering possession of property, specific performance of contracts, and outlines which contracts can and cannot be specifically enforced.
- It establishes that specific relief can only be granted to enforce individual civil rights, not penal laws. Specific performance of contracts depends on factors like whether compensation is adequate and whether the court can supervise performance.
- The Act specifies who can obtain specific performance, such as parties to a contract or their representatives, and limits it in some
1. Short title, extent and commencement.—(1) This Act may be called the Specific Relief Act, 1963.
(2) It extends to the whole of India except the State of Jammu and Kashmir.
(3) It shall come into force on such date 1 as the Central Government may, by notification in the Official Gazette, appoint.
This document appears to be part of an act from Bangladesh related to specific relief. It begins with a preamble stating it is to define and amend the law relating to certain kinds of specific relief obtainable in civil suits. It then provides definitions for terms used in the act like obligation, trust, and trustee. The act discusses different types of specific relief that can be granted, including taking possession of property, ordering a party to perform an act, and preventing a party from acting. It provides guidance on recovering possession of both immovable and movable property and on the specific performance of contracts.
he Specific Relief Act, 1963 is an Act of the Parliament of India which provides remedies for persons whose civil or contractual rights have been violated. It replaced an earlier Act of 1877. The following kinds of remedies may be granted by a court under the provisions of the Specific Relief Act:
Recovery of possession of property
Specific performance of contracts
Rectification of instruments
Rescission of contracts
Cancellation of Instruments
Declaratory decrees
Injunction
This document provides the definitions and preliminary information for the Code of Civil Procedure, 1908 in Bangladesh. It defines key terms used in the code such as "decree", "judgment", "pleader", and "public officer". It also outlines some general principles for Bangladeshi civil procedure such as which courts have jurisdiction over which types of suits, the concept of res judicata, and where suits should be instituted based on the location of the subject matter in dispute.
The document is an excerpt from the Limitation Act, 1908 of Bangladesh. It discusses provisions related to computing periods of limitation for filing lawsuits, appeals or applications. Some key points:
- It excludes time during which the defendant was absent from Bangladesh or certain other territories.
- It excludes time during which the plaintiff was prosecuting another case in good faith against the same defendant but the court lacked jurisdiction.
- It excludes time during which a proceeding was stayed by an injunction or order, and the time for which any notice was given according to law.
- Special provisions apply if the right to sue accrued but the person with the right or the potential defendant died before the right accrued or the case
This document is the preamble and introductory chapter of the Penal Code of Bangladesh from 1860. It establishes the title and extent of operation for the Penal Code, noting that it shall take effect throughout Bangladesh. It also establishes that individuals shall be liable under this Code for offenses committed within Bangladesh, and that some provisions extend extraterritorial application for offenses committed by Bangladeshi citizens or on ships/aircraft registered in Bangladesh wherever located. Finally, it provides initial definitions for terms that are used throughout the Code, such as "public servant", "wrongful gain/loss", and "document".
Liability Insurance is available to protect you against liability arising out of any accident affecting any person(s) occurring while handling hazardous substances. Came into force on 01st April 1991
AMENDMENTS TO SARFAESI ACT/RULES/DRT ACT AND RULES WHICH HAVE BEEN ENFORCEDMukesh Chand
The document summarizes key amendments to the Security Interest (Enforcement) Rules, 2002 and the Debt Recovery Tribunal (Procedure) Rules, 1993 in India that came into effect from November 4, 2016. Some of the major changes include:
1) Allowing delivery of notices by hand delivery in addition to other modes.
2) Reducing the notice period for subsequent auctions of secured assets from 30 days to 15 days.
3) Allowing service of notices via email in addition to other modes.
4) Providing for public auctions, including e-auctions of secured assets.
5) Reducing timelines for filing written statements and replies in DRT recovery applications.
This is a special Act.Though it has less sections but all are very effective. The Court can see this Act as guidance to use its discretion in judicious manner.
This document provides an overview of specific relief under Indian law. It discusses key concepts like specific performance of contracts and recovery of possession of property. Specific relief refers to a form of judicial remedy where a party is compelled by a civil court to do or refrain from doing a certain act. The Specific Relief Act of 1877 governs specific relief in India and is based on principles of equity. It allows for specific performance of contracts for sale of immovable property, partial performance of contracts where part of the obligation cannot be fulfilled, and rights of purchasers against vendors with imperfect title. Certain types of contracts cannot be specifically enforced, such as those requiring continuous performance over 3 years or those with uncertain terms.
The document provides an overview of benami transactions and the Benami Transactions (Prohibition) Act 1988 in India. Some key points:
- Benami means "property without name" and refers to transactions where property is purchased in someone else's name without intending to benefit them.
- The 1988 Act was introduced to prohibit benami transactions and recover properties held benami, as such transactions were previously abused to evade taxes, circumvent land ceilings, and commit fraud.
- Under the Act, benami transactions are prohibited and no suits can be filed to claim rights over benami properties. Benami properties are also liable for acquisition by authorities. However, the Act had deficiencies in implementation and scope
The Reserve Bank of India regulates the establishment of branches, liaison offices, or other places of business in India by foreign companies. No foreign company can set up such an office without RBI approval, except for banking and insurance companies regulated by other acts. Foreign companies can also set up standalone branches in Special Economic Zones to conduct permitted business activities without RBI approval if they meet certain conditions. The regulations specify the application process and permitted activities of foreign branches and liaison offices in India.
The document summarizes key aspects of the Benami Transactions (Prohibition) Amendment Act 2016 in India. It defines benami transactions as purchasing or holding property in someone else's name while providing the consideration. The Act aims to prohibit benami transactions and allow for confiscation of benami properties. It establishes authorities like initiating officers, adjudicating authorities, and an appellate tribunal to oversee the attachment, adjudication and confiscation of benami properties. Penalties for offenses include fines up to 25% of fair market value and imprisonment from 1-7 years. The Act is expected to impact the real estate market by reducing black money transactions and property disputes.
Conditional Sale and Purchase Agreement / Contract (Purchase this doc, Text: ...GLC
This document outlines a conditional sale and purchase agreement between multiple parties for shares in a company. Key points:
- The sellers agree to sell their shares in the company to the purchaser, subject to certain terms and conditions being met.
- The purchase price for the shares is specified for each seller. Payment is due within 3 months of signing the agreement.
- Several conditions must be fulfilled before and after payment, including obtaining necessary approvals.
- Failure to meet the conditions or make payment on time results in default consequences like termination of the agreement or repayment of funds.
- Disputes will be resolved via arbitration in Indonesia and governed by Indonesian law. The parties agree not to pursue matters
The document provides an overview of the Specific Relief Act 1963 in India. It discusses:
1) The Act defines and amends the law relating to specific relief for enforcing civil rights. It does not apply to penal rights.
2) The Act provides for seven types of specific relief: recovery of possession of property, specific performance of contracts, rectification of instruments, rescission of contracts, cancellation of instruments, declaratory decrees, and preventive relief.
3) Specific performance of contracts can be granted for immovable property transactions but generally not for movable property where compensation is adequate.
The document discusses benami transactions under Indian law. It defines key terms like benamidar and beneficial owner. It summarizes the Benami Transactions (Prohibition) Act of 1988 and the 2011 bill that replaced it. The bill prohibits benami transactions and makes property involved liable for confiscation. It imposes penalties for engaging in benami transactions or providing false information regarding such transactions.
This document is the Evidence Act of 1872 from Bangladesh. It defines key terms used in evidence and testimony such as "court", "fact", "document", and "evidence". It also outlines the relevance of different types of facts that can be presented as evidence, such as facts that are part of the same transaction, facts that provide motive or context, and facts that are necessary to explain other facts in the case. The document establishes the framework for how evidence is treated and presented in legal proceedings in Bangladeshi courts.
CONVENTIONBETWEENTHE ROYAL GOVERNMENT OF THAILANDANDTHE GOVERNMENT.docxmaxinesmith73660
This document outlines a convention between Thailand and Singapore to avoid double taxation and prevent tax evasion on income. It details that the governments desire to conclude an agreement (Article 1), the taxes covered which include income taxes (Article 2), definitions of terms like resident and permanent establishment (Articles 3-5), and how to tax different types of income including business profits, shipping/air transport, associated enterprises, dividends, and interest (Articles 6-11). The purpose is to establish a framework for taxing income of residents in one or both countries in order to eliminate double taxation.
This document is a convention between Moldova and Bosnia and Herzegovina to avoid double taxation and prevent tax evasion on income and property taxes. It outlines how income earned in one country by residents of the other will be taxed. It defines terms like resident, permanent establishment, and outlines which specific taxes are covered. It also provides rules for taxing business profits, international transportation income, property income, and dividends between the two countries.
Double taxation avoidance agreement between india and canadarhejkrhfkBaivabiNayak
The document discusses the Double Taxation Avoidance Agreement (DTAA) between India and Canada. Some key points:
- The DTAA was signed in 1985 and came into effect in 1997 to help taxpayers avoid double taxation on the same income earned in both countries.
- It applies to taxes on income and capital imposed by India and Canada. This includes taxes on things like profits, dividends, interest, royalties.
- The DTAA defines terms like residence, permanent establishment, and outlines how different types of income like business profits, shipping/air transport income, capital gains, pensions are taxed under the agreement.
- The overall aim is to help residents of both countries avoid being tax
This document is an agreement between the governments of the United States and Vietnam to avoid double taxation and prevent tax evasion on income. It defines key terms like "resident", "permanent establishment", and outlines which taxes are covered. It also establishes rules for attributing taxable income to permanent establishments and determining deductions. The agreement aims to provide clarity on tax obligations and ensure neither country taxes the same income twice.
This document provides an overview and definitions for key terms in the Financial Rehabilitation and Insolvency Act of 2010 in the Philippines. It defines terms like debtor, claim, commencement date, rehabilitation, and liquidation. It also outlines exclusions from the Act, such as banks and insurance companies. The Act aims to encourage rehabilitation of financially distressed enterprises when possible, and orderly liquidation when rehabilitation is not feasible, to protect creditor rights and maximize asset value.
Vietnam LAW ON ENTERPRISES - Anphabe.Comduynguyentt
This Vietnam Enterprises Law provides for the establishment, management organization and operation of limited
liability companies, shareholding companies, partnerships and private enterprises in all economic
sectors (hereinafter referred to as enterprises); provides for corporate groups.
This document defines key concepts related to persons under tax law, including individuals, associations of persons, and companies. It provides that an individual, company, association of persons, government, or public international organization shall be treated as a person. It also defines resident and non-resident persons and provides principles for taxing individuals, associations of persons, and companies separately. Income of a company's shareholders from dividends is taxed separately from other income of the company.
This document is an agreement between the governments of Myanmar and Israel to promote and protect investments between the two countries. It defines key terms like "investment", "host country", "home country", and "investor". It establishes that each country will encourage favorable conditions for investments from the other and ensure fair treatment. Investments are guaranteed most-favored nation treatment and national treatment. The agreement also covers compensation for losses due to armed conflict, expropriation of property, and free transfer of investments and returns.
Uu tahun 2007 no. 40 tentang perseroan terbatas_eng. ver.Legal Akses
This document is the unofficial English translation of the Law of the Republic of Indonesia Number 40 of 2007 on Limited Liability Companies. The law establishes the legal framework for limited liability companies in Indonesia. It defines key terms related to companies, outlines requirements for company formation including minimum number of shareholders and contents of articles of association, and establishes rules regarding company administration such as the roles and responsibilities of company organs. The law aims to support national economic development by providing a strong legal basis for businesses to operate as limited liability companies in Indonesia.
This document summarizes the compulsory registration requirements under the Goods and Services Tax (GST) law in India. It outlines the aggregate turnover thresholds for requiring registration in different states and union territories. It also lists other specified cases where registration is compulsory, such as for inter-state suppliers, e-commerce operators, and persons supplying online information from outside India. The document provides definitions and explanations of key terms related to registration such as "person", "supplier", "business vertical", and "supply". It was prepared by Pradeep Goyal, a Chartered Accountant, for educational purposes to provide a general understanding of the GST registration requirements, not professional tax advice.
DIRECTORATE OF INVESTMENT AND COMPANY ADMINISTRATION MYANMAR -DOWNLOAD FILE C...MYO AUNG Myanmar
http://www.dica.gov.mm/en
The Directorate of Investment and Company Administration (DICA) is in charge of handling company registrations for local and foreign businesses under the Companies Act. DICA also serves as a secretary to the Myanmar Investment Commission (MIC), which is the responsible body for investment applications.
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DICA
MIC
DEPARTMENTAL COOPERATION TEAM
CONTACT
ARCHIVE FOR DOCUMENTS
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+951 657891
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dica@mptmail.net.mm
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Research Interests: Myanmar, Asset and investment valuation, and MYANMAR INVESTMENT LAW
This document is the Integrated Goods and Services Tax Bill, 2017. It contains 25 definitions that are relevant for understanding and implementing the Integrated Goods and Services Tax. Key terms defined include integrated tax, place of supply, export and import of goods and services, online information and database access services, and zero-rated supply. The bill aims to levy and collect tax on inter-state supply of goods or services by the Central Government.
This document is a treaty between the United States and Bangladesh concerning investment protection and encouragement. It aims to promote economic cooperation by establishing rules for investments made by nationals and companies of one country in the territory of the other. Key provisions include: (1) requiring each country to provide fair and equitable treatment of investments from the other; (2) establishing rules for compensation in cases of expropriation of investments; (3) allowing for the free transfer of funds associated with investments; and (4) creating mechanisms for consultation and dispute settlement related to investments covered by the treaty.
The document discusses underwriting, which is an agreement where underwriters take on the risk of purchasing securities from an issuer in the event that the public demand is insufficient. It describes different types of underwriting arrangements and the roles and responsibilities of underwriters. It also outlines the eligibility criteria, registration process, operational guidelines, and record keeping requirements for underwriters according to SEBI regulations in India. As an example, it summarizes that Alibaba's 2014 IPO raised over $20 billion with six major banks serving as equal lead underwriters.
Magnetic resonance imaging (MRI) is a medical imaging technique that uses a magnetic field and computer-generated radio waves to create detailed images of the organs and tissues in your body.
Most MRI machines are large, tube-shaped magnets. When you lie inside an MRI machine, the magnetic field temporarily realigns water molecules in your body. Radio waves cause these aligned atoms to produce faint signals, which are used to create cross-sectional MRI images — like slices in a loaf of bread.
The MRI machine can also produce 3D images that can be viewed from different angles.
Products & Services
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Why it's done
MRI is a noninvasive way for your doctor to examine your organs, tissues and skeletal system. It produces high-resolution images of the inside of the body that help diagnose a variety of problems.
MRI of the brain and spinal cord
MRI is the most frequently used imaging test of the brain and spinal cord. It's often performed to help diagnose:
Aneurysms of cerebral vessels
Disorders of the eye and inner ear
Multiple sclerosis
Spinal cord disorders
Stroke
Tumors
Brain injury from trauma
A special type of MRI is the functional MRI of the brain (fMRI). It produces images of blood flow to certain areas of the brain. It can be used to examine the brain's anatomy and determine which parts of the brain are handling critical functions.
This helps identify important language and movement control areas in the brains of people being considered for brain surgery. Functional MRI can also be used to assess damage from a head injury or from disorders such as Alzheimer's disease.
MRI of the heart and blood vessels
MRI that focuses on the heart or blood vessels can assess:
Size and function of the heart's chambers
Thickness and movement of the walls of the heart
Extent of damage caused by heart attacks or heart disease
Structural problems in the aorta, such as aneurysms or dissections
Inflammation or blockages in the blood vessels
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1. To trade in the domestic market in Patna, Bihar, key documents required include registration for Central Sales Tax (CST), Bihar Value Added Tax (VAT), and a labour certificate.
2. For the CST and VAT registrations, documents like identity proof, address proof, municipality receipts, and bank statements must be submitted to the local sales tax office.
3. Quarterly tax returns also need to be filed showing goods purchased and sold, along with proof of tax paid. A road permit form is required for inter-state purchases, while an internal C form allows payment of a lower 2% CST rate versus 5% without the form.
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Vicinity Jobs’ data includes more than three million 2023 OJPs and thousands of skills. Most skills appear in less than 0.02% of job postings, so most postings rely on a small subset of commonly used terms, like teamwork.
Laura Adkins-Hackett, Economist, LMIC, and Sukriti Trehan, Data Scientist, LMIC, presented their research exploring trends in the skills listed in OJPs to develop a deeper understanding of in-demand skills. This research project uses pointwise mutual information and other methods to extract more information about common skills from the relationships between skills, occupations and regions.
5 Tips for Creating Standard Financial ReportsEasyReports
Well-crafted financial reports serve as vital tools for decision-making and transparency within an organization. By following the undermentioned tips, you can create standardized financial reports that effectively communicate your company's financial health and performance to stakeholders.
The Universal Account Number (UAN) by EPFO centralizes multiple PF accounts, simplifying management for Indian employees. It streamlines PF transfers, withdrawals, and KYC updates, providing transparency and reducing employer dependency. Despite challenges like digital literacy and internet access, UAN is vital for financial empowerment and efficient provident fund management in today's digital age.
Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
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A toxic combination of 15 years of low growth, and four decades of high inequality, has left Britain poorer and falling behind its peers. Productivity growth is weak and public investment is low, while wages today are no higher than they were before the financial crisis. Britain needs a new economic strategy to lift itself out of stagnation.
Scotland is in many ways a microcosm of this challenge. It has become a hub for creative industries, is home to several world-class universities and a thriving community of businesses – strengths that need to be harness and leveraged. But it also has high levels of deprivation, with homelessness reaching a record high and nearly half a million people living in very deep poverty last year. Scotland won’t be truly thriving unless it finds ways to ensure that all its inhabitants benefit from growth and investment. This is the central challenge facing policy makers both in Holyrood and Westminster.
What should a new national economic strategy for Scotland include? What would the pursuit of stronger economic growth mean for local, national and UK-wide policy makers? How will economic change affect the jobs we do, the places we live and the businesses we work for? And what are the prospects for cities like Glasgow, and nations like Scotland, in rising to these challenges?
In a tight labour market, job-seekers gain bargaining power and leverage it into greater job quality—at least, that’s the conventional wisdom.
Michael, LMIC Economist, presented findings that reveal a weakened relationship between labour market tightness and job quality indicators following the pandemic. Labour market tightness coincided with growth in real wages for only a portion of workers: those in low-wage jobs requiring little education. Several factors—including labour market composition, worker and employer behaviour, and labour market practices—have contributed to the absence of worker benefits. These will be investigated further in future work.
Abhay Bhutada, the Managing Director of Poonawalla Fincorp Limited, is an accomplished leader with over 15 years of experience in commercial and retail lending. A Qualified Chartered Accountant, he has been pivotal in leveraging technology to enhance financial services. Starting his career at Bank of India, he later founded TAB Capital Limited and co-founded Poonawalla Finance Private Limited, emphasizing digital lending. Under his leadership, Poonawalla Fincorp achieved a 'AAA' credit rating, integrating acquisitions and emphasizing corporate governance. Actively involved in industry forums and CSR initiatives, Abhay has been recognized with awards like "Young Entrepreneur of India 2017" and "40 under 40 Most Influential Leader for 2020-21." Personally, he values mindfulness, enjoys gardening, yoga, and sees every day as an opportunity for growth and improvement.
OJP data from firms like Vicinity Jobs have emerged as a complement to traditional sources of labour demand data, such as the Job Vacancy and Wages Survey (JVWS). Ibrahim Abuallail, PhD Candidate, University of Ottawa, presented research relating to bias in OJPs and a proposed approach to effectively adjust OJP data to complement existing official data (such as from the JVWS) and improve the measurement of labour demand.
Economic Risk Factor Update: June 2024 [SlideShare]Commonwealth
May’s reports showed signs of continued economic growth, said Sam Millette, director, fixed income, in his latest Economic Risk Factor Update.
For more market updates, subscribe to The Independent Market Observer at https://blog.commonwealth.com/independent-market-observer.
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Tax treaty indonesia south korea
1. AGREEMENT BETWEEN
THE GOVERNMENT OF THE REPUBLIC OF INDONESIA
AND
THE GOVERNMENT OF THE REPUBLIC OF KOREA
FOR THE AVOIDANCE OF DOUBLE TAXATION AND
THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
Article 1
PERSONAL SCOPE
This Agreement shall apply to persons who are residents of one or both of the Contracting States.
Article 2
TAXES COVERED
1. This Agreement shall apply to taxes on income imposed on behalf of each Contracting
State, irrespective of the manner in which they are levied.
2. There shall be regarded as taxes on income all taxes imposed on total income or on
elements of income, including taxes on gains from the alienation of movable or
immovable property and taxes on the total amounts of wages or salaries paid by
enterprises.
3. The taxes which are the subject of this Agreement are:
(a) in Indonesia :
the income tax (Pajak Penghasilan), and to the extent provided in such income tax,
the company tax (Pajak Perseroan), and
the tax on interest, dividends, and royalties (Pajak atas Bunga, Dividen dan
Royalti);
(hereinafter referred to as "Indonesian Tax");
(b) in Korea:
(i) the income tax;
(ii) the cooperation tax;
(iii) the inhabitant tax where charged by reference to the income tax or the
corporation;
(hereinafter referred to as "Korean Tax").
4. This Agreement shall also apply to any identical or substantially similar taxes on income
which are imposed after the date of signature of this Agreement in addition to, or in place
of, those referred to in paragraph 3.
The competent authorities of the Contracting States shall notify each other of any
substantial changes which have been made in their respective taxation laws.
Article 3
GENERAL DEFINITIONS
2. 1. In this Agreement, unless the context otherwise requires:
(a) (i) the term "Indonesia" comprises the territory of the Republic of Indonesia as
defined in its laws and parts of the continental shelf and adjacent seas, over
which the Republic of Indonesia has sovereignty, sovereign rights or other
rights in accordance with international law;
(ii) the term "Korea" comprises the territory of the Republic of Korea as defined in
its laws and parts of the continental shelf and adjacent seas, over which the
Republic of Korea has sovereignty, sovereign rights or other rights in
accordance with international law;
(b) the terms "a Contracting State" and "the other Contracting State" mean Indonesia or
Korea as the context requires;
(c) the term "tax" means Indonesian tax or Korean tax, as the context requires;
(d) the term "person" includes an individual, a company and any other body of persons
which is treated as an entity for tax purposes;
(e) the term "company" means any body corporate or any entity which is treated as a
body corporate for tax purposes;
(f) 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;
(g) 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;
(h) the term "competent authority" means :
(i) in Indonesia: the Minister of Finance or his authorized representative;
(ii) in Korea: the Minister of Finance or his authorized representative;
(i) the term "national" means :
(a) all individuals possessing the nationality of a Contracting State;
(b) all legal persons, partnerships and associations deriving their status as such
from the laws in force in a Contracting State.
2. As regards the application of this Agreement by a Contracting State, any term not defined
in this Agreement shall, unless the context otherwise requires, have the meaning which it
has under the laws of that Contracting State concerning the taxes to which this
Agreement applies.
Article 4
RESIDENT
1. For the purposes of this Agreement, the term "resident of a Contracting State" means any
person who, under the laws of that Contracting State, is treated as a resident for tax
purposes in that Contracting State. But this term does not include any person who is
liable to tax in that State in respect only of income from sources in that State.
2. 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:
3. (a) 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);
(b) 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;
(c) if he has an habitual abode in both States or in neither of them, the competent
authorities of the two Contracting States shall settle the question by mutual
agreement.
3. Where by reason of the provisions of paragraph 1 a person other than an individual is a
resident of both Contracting States, then it shall be deemed to be a resident of the State in
which its place of effective management is situated.
Article 5
PERMANENT ESTABLISHMENT
1. For the purpose of this Agreement the term "permanent establishment" means a fixed
place of business through which the business of an enterprise is wholly or partly carried
on.
2. The term "permanent establishment" includes especially:
(a) a place of management;
(b) a branch;
(c) an office;
(d) a factory
(e) a workshop; and
(f) a mine, an oil or gas well, a quarry or any other place of extraction of natural
resources.
3. The term "permanent establishment" likewise encompasses:
(a) A building site or construction project or supervisory activities in connection
therewith, where such site, project or activities continue for a period of more than
six months;
(b) An assembly or installation project which exists for more than six months;
(c) The furnishing of services, including consultancy services, by an enterprise through
employees or other persons engaged by the enterprise for such purpose, but only
where activities of that nature continue (for the same or a connected project) within
the country for a period or periods aggregating more than three months within any
period of twelve months.
4. Notwithstanding the preceding provisions of this Article, the term "permanent
establishment" shall be deemed not to include:
4. (a) The use of facilities solely for the purpose of storage or display of goods or
merchandise belonging to the enterprise;
(b) The maintenance of a stock of goods or merchandise belonging to the enterprise
solely for the purpose of storage or display;
(c) The maintenance of a stock of goods or merchandise belonging to the enterprise
solely for the purpose of processing by another enterprise;
(d) The maintenance of a fixed place of business solely for the purpose of purchasing
goods or merchandise or of collecting information, for the enterprise;
(e) The maintenance of a fixed place of business solely for the purpose of carrying on,
for the enterprise, any other activity of a preparatory or auxiliary character.
5. Notwithstanding the provisions of paragraphs 1 and 2, where a person other than an agent
of an independent status to whom paragraph 7 applies 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 Contracting State in respect of any
activities which that person undertakes for the enterprise, if such a person:
(a) has and habitually exercises in that State an authority to conclude contracts in the
name of the enterprise, unless the activities of such person are limited to those
mentioned in paragraph 4 which, if exercised through a fixed place of business,
would not make this fixed place of business a permanent establishment under the
provisions of that paragraph; or
(b) has no such authority, but habitually maintains in the first-mentioned State a stock
of goods or merchandise from which he regularly delivers goods or merchandise on
behalf of the enterprise.
6. An insurance enterprise of a Contracting State shall, except with regard to reinsurance, be
deemed to have a permanent establishment in the other Contracting State if it collects
premiums in that other Contracting State or insures risks situated therein through an
employee or through a representative who is not an agent of an independent status within
the meaning of paragraph 7.
7. An enterprise of a Contracting State shall not be deemed to have a permanent
establishment in the other Contracting State merely because it carries on business in that
other Contracting State through a broker, general commission agent or any other agent of
an independent status, provided that such persons are acting in the ordinary course of
their business.
However, when 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.
8. The fact that a company which is a resident of a Contracting State controls or is
controlled by a company which is a resident of the other Contracting State, or which
carries on business in that other Contracting State (whether through a permanent
establishment or otherwise), shall not of itself constitute either company a permanent
establishment of the other.
5. Article 6
INCOME FROM IMMOVABLE PROPERTY
1. 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.
2. The term "immovable property" shall have the meaning which it has under the law of the
Contracting State in which the property in question is situated. The term shall in any case
include property accessory to immovable property, livestock and equipment used in
agriculture and forestry, rights to which the provisions of general law respecting landed
property apply, usufruct of immovable property and rights to variable or fixed payments
as consideration for the working of, or the right to work, mineral deposits, sources and
other natural resources; ships, boats and aircraft shall not be regarded as immovable
property.
3. The provisions of paragraph 1 shall apply to income derived from the direct use, letting,
or use in any other form of immovable property.
4. The provisions of paragraphs 1 and 3 shall apply to the income from immovable property
of an enterprise and to income from immovable property used for the performance of
independent personal services.
Article 7
BUSINESS PROFITS
1. The profits of an enterprise of a Contracting State shall be taxable only in that State
unless the enterprise carries on business in the other Contracting State through a
permanent establishment situated therein. 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 are attributable to that permanent establishment, or to the sale of goods or
merchandise of the same kind as those sold, or to other business transactions of the same
kind as those effected, through the permanent establishment.
2. Subject to the provisions of paragraph 3 where an enterprise of a Contracting State carries
on business in the other Contracting State through a permanent establishment situated
therein, there shall in each Contracting State be attributed to that permanent
establishment the profits which it might be expected to make if it were a distinct and
separate enterprise engaged in the same or similar activities under the same or similar
conditions and dealing wholly independently with the enterprise of which it is a
permanent establishment.
3. 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 incurred in the State in which the permanent establishment is situated or
elsewhere. However, no such deduction shall be allowed in respect of amounts, if any,
paid (otherwise than towards reimbursement of actual expenses) by 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
6. the case of a banking enterprise, by way of interest on moneys lent to the permanent
establishment.
Likewise, no account shall be taken, in the determination of the profits of a permanent
establishment, for amounts charged (otherwise than toward reimbursement of actual
expenses), by 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.
4. For the purpose of the preceding paragraphs, the profits to be attributed to the permanent
establishment shall be determined by the same method year by year unless there is good
and sufficient reason to the contrary.
5. Where profits include items of income which are dealt with separately in other Articles,
then the provisions of those Articles shall not be affected by the provisions of this
Article.
6. No profits shall be attributed to a permanent establishment by reason of the mere
purchase by that permanent establishment of goods or merchandise for the enterprise.
Article 8
SHIPPING AND AIR TRANSPORT
1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in
international traffic shall be taxable only in that State.
2. The provision of paragraph 1 shall also apply to profits derived from the participation in a
pool, a joint business or an international operation agency.
3. In respect of the operation of ships or aircraft in international traffic carried on by an
enterprise of a Contracting State, that enterprise, if an enterprise of Indonesia, shall also
be exempt from the value added tax in Korea and, if an enterprise of Korea, shall also be
exempt from any tax similar to the value added tax in Korea which may hereafter be
imposed in Indonesia.
Article 9
ASSOCIATED ENTERPRISES
1. Where:
(a) an enterprise of a Contracting State participates directly or indirectly in the
management, control or capital of an enterprise of the other Contracting State,
or
(b) the same persons participate directly or indirectly in the management, control
or capital of an enterprise of a Contracting State and an enterprise of the other
Contracting State,
and in either case conditions are made or imposed between the two enterprises in their
commercial or financial relations which differ from those which would be made between
independent enterprises, then any profits which would, but for those conditions, have
accrued to one of the enterprises, but, by reason of those conditions, have not so accrued,
7. may be included in the profits of that enterprise and taxed accordingly.
2. Where a Contracting State includes in the profits of an enterprise of that State -- and taxes
accordingly -- profits on which an enterprise of the other Contracting State has been
charged to tax in that other State and the profits so included are profits which would have
accrued to the enterprise of the first-mentioned State if the conditions made between the
two enterprises had been those which would have been made between independent
enterprises, then that other State shall make an appropriate adjustment to the amount of
the tax charged therein on those profits. In determining such adjustment, due regard shall
be had to the other provisions of this Agreement and the competent authorities of the
Contracting States shall if necessary consult each other.
Article 10
DIVIDENDS
1. Dividends paid by a company which is a resident of a Contracting State to a resident of
the other Contracting State may be taxed in that other Contracting State.
2. However, such dividends may also be taxed in the Contracting State of which the
company paying the dividends is a resident and according to the laws of that State, but if
the recipient is the beneficial owner of the dividends the tax so charged shall not exceed:
(a) 10% of the gross amount of the dividends if the beneficial owner is a company
(other than a partnership) which holds directly at least 25% of the capital of the
company paying the dividends;
(b) 15% of the gross amount of the dividends in all other cases.
This paragraph shall not affect the taxation of the company in respect of the profits out of
which the dividends are paid.
3. The term "dividends" as used in this Article means income from shares or other rights,
not being debt-claims, participating in profits, as well as income from other corporate
rights which is subjected to the same taxation treatment as income from shares by the
taxation laws of the Contracting State of which the company making the distribution is a
resident.
4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the
dividends, being a resident of a Contracting State, carries on business in the other
Contracting State of which the company paying the dividends is a resident, through a
permanent establishment situated therein, or performs in that other Contracting State
independent personal services from a fixed base situated therein, and the holding in
respect of which the dividends are paid is effectively connected with such permanent
establishment or fixed base. In such case, the provisions of Article 7 or Article 14, as the
case may be, shall apply.
5. Where a company which is a resident of a Contracting State derives profits or income
from the other Contracting State, that other Contracting State may not impose any tax on
the dividends paid by the company, except insofar as such dividends are paid to a resident
of that other Contracting State or insofar as the holding in respect of which the dividends
are paid is effectively connected with a permanent establishment or a fixed base situated
8. in that other Contracting State, nor subject the company's undistributed profits to a tax on
the company's undistributed profits, even if the dividends paid or the undistributed profits
consist wholly or partly of profits or income arising in that other Contracting State.
6. Notwithstanding any other provisions of this Agreement where a company which is a
resident of a Contracting State has a permanent establishment in the other Contracting
State, the profits of the permanent establishment may be subjected to an additional tax in
that other State in accordance with its law, but the additional tax so charged shall not
exceed 10% of the amount of such profits after deducting therefrom income tax and other
taxes on income imposed thereon in that other State.
7. The provisions of paragraph 6 of this Article shall not affect the provisions contained in
any production sharing contracts and contracts of work (or any other similar contracts)
relating to the oil and gas sector or other mining sector concluded on or before 31
December 1983, by the Government of Indonesia, its instrumentality, its relevant State
oil and gas company or any other entity thereof with a person who is resident of Korea.
Article 11
INTEREST
1. Interest arising in a Contracting State and paid to a resident of the other Contracting State
may be taxed in that other State.
2. However, such interest may also be taxed in the Contracting State in which it arises and
according to the laws of that State, but if the recipient is the beneficial owner of the
interest the tax so charged shall not exceed 10% of the gross amount of the interest.
3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting State and
derived by the Government of the other Contracting State including political subdivisions
and local authorities thereof, the Central Bank of that other Contracting State or any
financial institution wholly owned by that Government, or by any resident of the other
Contracting State with respect to debt-claims guaranteed or indirectly financed by the
Government of that other Contracting State including political subdivisions and local
authorities thereof, the Central Bank of that other Contracting State or any financial
institution wholly owned by that Government shall be exempt from tax in the first-
mentioned Contracting State.
4. For the purposes of paragraph 3, the term "the Central Bank" and "financial institution
wholly owned by the "Government" mean:
(a) in the case of Korea :
(i) the Bank of Korea;
(ii) the Korea Export - Import Bank;
(iii) the Korea Exchange Bank;
(iv) such other financial institution, the capital of which is wholly owned by the
Government of the Republic of Korea as may be agreed upon from time to time
between the Governments of the two Contracting States.
(b) In the case of Indonesia:
(i) the "Bank Indonesia" ,and
(ii) such other financial institution the capital of which is wholly owned by the
Government of the Republic of Indonesia as may be agreed upon from time to
9. time between Government of the two Contracting States.
5. The term "interest" as used in this Article means income from debt-claims of every kind,
whether or not secured by mortgage and whether or not carrying a right to participate in
the debtor's profits, and in particular income from government securities and income
from bonds or debentures, including premiums and prizes attaching to such securities,
bonds or debentures, as well as income assimilated to income from money lent by the
taxation laws of the State in which the income arises.
6. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the
interest, being a resident of a Contracting State, carries on business in the other
Contracting State in which the interest arises, through a permanent establishment situated
therein, or performs in that other Contracting State independent personal services from a
fixed base situated therein, and the debt-claim in respect of which the interest is paid is
effectively connected with such permanent establishment or fixed base. In such case, the
provisions of Article 7 or Article 14, as the case may be, shall apply.
7. Interest shall be deemed to arise in a Contracting State when the payer is that Contracting
State itself, a political subdivision or a local authority thereof, or a resident of that
Contracting State, where, however, the person paying the interest, whether he is a
resident of a Contracting State or not, has in a Contracting State a permanent
establishment or a fixed base in connection with which the indebtedness on which the
interest is paid was incurred, and such interest is borne by such permanent establishment
or fixed base, then such interest shall be deemed to arise in the Contracting State in which
the permanent establishment or fixed base is situated.
8. 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. In such case, the
excess part of the payments shall remain taxable according to the laws of each
Contracting State, due regard being had to the other provisions of this Agreement.
Article 12
ROYALTIES
1. Royalties arising in a Contracting State and paid to a resident of the other Contracting
State may be taxed in that other State.
2. However, such royalties may also be taxed in the Contracting State in which they arise
and according to the laws of that State, but if the recipient is the beneficial owner of the
royalties the tax so charged shall not exceed 15% of the gross amount of the royalties.
3. The term "royalties" as used in this Article means payments of any kind received as a
consideration for the use of, or the right to use, any copyright of literary, artistic or
scientific work including cinematograph film, or films or tapes for radio or television
broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or
for the use of, or the right to use, industrial, commercial or scientific equipment, or for
information concerning industrial, commercial or scientific experience.
10. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the
royalties, being a resident of a Contracting State, carries on business in the other
Contracting State in which the royalties arise, through a permanent establishment situated
therein, or performs in that other State independent personal services from a fixed base
situated therein, and the right or property in respect of which the royalties are paid is
effectively connected with such permanent establishment or fixed base. In such case, the
provisions of Article 7 or Article 14, as the case may be, shall apply.
5. Royalties shall be deemed to arise in a Contracting State when the payer is that State
itself, a political subdivision, a local authority or a resident of that State. Where, however,
the person paying the royalties, whether he is a resident of a Contracting State or not, has
in a Contracting State a permanent establishment or a fixed base in connection with
which the obligation to pay the royalties was incurred, and such royalties are borne by
such permanent establishment or fixed base, then such royalties shall be deemed to arise
in the State in which the permanent establishment or fixed base is situated.
6. 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 royalties, having regard
to the use, right or information for which they are 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.
In such case, the excess part of the payments shall remain taxable according to the laws
of each Contracting State, due regard being had to the other provisions of this
Agreement.
Article 13
CAPITAL GAINS
1. Capital gains from the alienation of immovable property as defined in paragraph 2 of
Article 6 may be taxed in the state in which such property is situated.
2. 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 with the whole enterprise) or of such fixed base, may
be taxed in that other State.
3. Gains from the alienation of ships or aircraft operated in international traffic or movable
property pertaining to the operation of such ships or aircraft shall be taxable only in the
Contracting State of which the enterprise is a resident.
4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2
and 3, shall be taxable only in the Contracting State of which the alienator is a resident.
Article 14
INDEPENDENT PERSONAL SERVICE
1. Income derived by an individual who is a resident of a Contracting State in respect of
professional services or other activities of an independent character shall be taxable only
11. in that Contracting State unless he has a fixed base regularly available to him in the other
Contracting State for the purpose of performing his activities or he is present in that other
Contracting State for a period or periods exceeding in the aggregate 90 days in the
calendar year concerned. If he has such a fixed base or remains in that other Contracting
State for the aforesaid period or periods, the income may be taxed in that other
Contracting State but only so much of it as is attributable to that fixed base or is derived
in that other Contracting State during the aforesaid period or periods.
2. The term "professional services" includes, especially, independent scientific, literary,
artistic, educational or teaching activities as well as the independent activities of
physicians, lawyers, engineers, architects, dentists and accountants.
Article 15
DEPENDENT PERSONAL SERVICE
1. Subject to the provisions of Articles 16, 18, 19, 20 and 21 salaries, wages and other
similar remuneration derived by a resident of a Contracting State in respect of an
employment shall be taxable only in that State unless the employment is exercised in the
other Contracting State. If the employment is so exercised, such remuneration as is
derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a
Contracting State in respect of an employment exercised in the other Contracting State
shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the
aggregate 183 days in the fiscal year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of
the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which
the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an
employment exercised aboard a ship or aircraft operated in international traffic by an
enterprise of a Contracting State, shall be taxable only in that State.
Article 16
DIRECTORS' FEES
Directors' fees and other similar payments derived by a resident of a Contracting State in his
capacity as a member of the board of directors of a company which is a resident of the other
Contracting State may be taxed in that other Contracting State.
Article 17
ARTISTES AND ATHLETES
1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a
Contracting State as an entertainer, such as a theatre, motion picture, radio or television
12. artiste, or a musician, or as an athlete, from his personal activities as such, may be taxed
in the other Contracting State in which these activities of the entertainer or athlete are
exercised.
Such income shall, however, be exempt from tax in that other Contracting State if such
activities are exercised by an individual, being a resident of that Contracting State,
pursuant to a special programme for cultural exchange agreed upon between he
Governments of the two Contracting States.
2. Where income in respect of personal activities as such of an entertainer or athlete accrues
not to that entertainer or athlete himself but to another person, that income may,
notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the Contracting State
in which the activities of the entertainer or athlete are exercised.
Such income shall, however, be exempt from tax in that Contracting State if such income
is derived from the activities exercised by an individual, being a resident of the other
Contracting State, pursuant to a special programme for cultural exchange agreed upon
between the Government of the two Contracting States and accrues to another person
who is a resident of that other Contracting State.
Article 18
PENSIONS
Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration
paid to a resident of a Contracting State in consideration of past employment may be taxed in
that Contracting State.
However, such pensions may also be taxed in the other Contracting State if the payment is made
by a resident of that State or a permanent establishment situated therein.
Article 19
GOVERNMENT SERVICE
1. (a) Remuneration, other than a pension, paid by a Contracting State, or a political
subdivision, or a local authority thereof, to an individual in respect of services
rendered to that Contracting State, or political subdivision or local authority thereof,
shall be taxable only in that Contracting State.
(b) However, such remuneration shall be taxable only in the other Contracting State if
the services are rendered in that other Contracting State and the individual is a
resident of that other Contracting State who:
(i) is a national of that other Contracting State; or
(ii) did not become a resident of that other Contracting State solely for the
purpose of performing the services.
2. (a) Any pension paid by, or out of funds created by, a Contracting State or a political
subdivision or a local authority thereof to an individual in respect of services
rendered to that Contracting State or political subdivision or local authority thereof
shall be taxable only in that Contracting State.
(b) However, such pension shall be taxable only in the other Contracting State if the
individual is a resident of, and a national of, that other Contracting State.
13. 3. The provisions of Articles 15, 16, 17 and 18 shall apply to remuneration and pensions in
respect of services rendered in connection with a business carried on by a Contracting
State or a political subdivision or a local authority thereof.
4. The provisions of paragraphs 1 and 2 of this Article shall likewise apply in respect of
remuneration or pensions paid, in the case of Korea, by the Bank of Korea, the Export-
Import Bank of Korea, the Korea Exchange Bank, the Korea Trade Promotion Corporation
and other government owned institutions performing functions of a governmental nature as
may be agreed upon from time to time by the Governments of the two Contracting States
and, in the case of Indonesia, by the Bank of Indonesia, the Development Bank of
Indonesia (Bank Penbangunan Indonesia), the National Savings Bank (Bank Tabungan
Negara) and other government owned institutions performing functions of a governmental
nature as may be agreed upon from time to time by the Governments of the two
Contracting States.
Article 20
TEACHERS
A professor or teacher who makes a temporary visit to a Contracting State for a period not
exceeding two years solely for the purpose of teaching or conducting research at a university,
college, school or other accredited educational institution, and who is, or immediately before
such visit was, a resident of the other Contracting State shall be taxable only in that other
Contracting State in respect of remuneration for such teaching or research.
Article 21
STUDENTS
Payments which a student, apprentice or business trainee who is or was immediately before
visiting a Contracting State a resident of the other Contracting State and who is present in the
first-mentioned Contracting State solely for the purpose of his education or training receives for
the purpose of his maintenance, education or training shall not be taxed in that first-mentioned
State, provided that such payments are made to him from sources outside that State.
Article 22
INCOME NOT EXPRESSLY MENTIONED
1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in
the foregoing Articles of this Agreement shall be taxable only in that Contracting State.
2. The provisions of paragraph 1 shall not apply to income, other than income from
immovable property as defined in paragraph 2 of Article 6, if the recipient of such
income, being a resident of a Contracting State, carries on business in the other
Contracting State through a permanent establishment situated therein, or performs in that
other Contracting State independent personal services from a fixed base situated therein,
and the right or property in respect of which the income is paid is effectively connected
with such permanent establishment or fixed base. In such case, the provisions of Article 7
or Article 14, as the case may be, shall apply.
14. Article 23
RELIEF FROM DOUBLE TAXATION
1. In the case of a resident of Korea, double taxation shall be avoided as follows:
Subject to the provisions of Korean tax law regarding the allowance as a credit against
Korean tax of tax payable in any country other than Korea (which shall not affect the
general principle hereof), the Indonesian tax payable (excluding, in the case of a
dividend, tax payable in respect of the profits out of which the dividend is paid) under the
laws of Indonesia and in accordance with this Agreement, whether directly or by
deduction, in respect of income from sources within Indonesia shall be allowed as a
credit against Korean tax payable in respect of that income. The credit shall not, however,
exceed that proportion of Korean tax which the income from sources within Indonesia
bears to the entire income subject to Korean tax.
2. For the purpose of paragraph 1, the term "Indonesian tax payable" shall be deemed to
include the amount of Indonesian tax which would have been payable in accordance with
Indonesian tax laws but for the exemption or reduction on dividends of Indonesian tax in
accordance with Indonesian laws relating to incentives for the promotion of economic
development in Indonesia which were in force on the date of signature of this Agreement
or any other provisions which may subsequently be introduced in Indonesia in
modification of, or in addition to, those laws so far as they are agreed by the competent
authorities of the Contracting State to be of a substantially similar character, provided
that the amount of the tax referred to in this paragraph shall, however, be an amount of
10% of the gross amount of such dividends.
3. In the case of Indonesia, double taxation shall be avoided as follows:
(a) Indonesia, when imposing tax on residents of Indonesia, may include in the basis
upon which such tax is imposed the items of income which may be taxed in Korea
in accordance with the provisions of this Agreement;
(b) Where a resident of Indonesia derives income from Korea and that income may be
taxed in Korea in accordance with the provisions of this Agreement, the amount of
Korean tax payable in respect of the income shall be allowed as a credit against the
Indonesian tax imposed on that resident.
The amount of credit, however, shall not exceed that part of the Indonesian tax, which is
appropriate to the income.
4. For the purpose of paragraph 3, the term "Korean tax payable" shall be deemed to include
the amount of Korean tax which would have been payable in accordance with Korean tax
laws but for the exemption or reduction on dividends of Korean tax in accordance with
the Korean laws relating to incentives for the promotion of economic development in
Korea which were in force on the date of signature of this Agreement or any other
provisions which may subsequently be introduced in Korea in modification of, or in
addition to, those laws so far as they are agreed by the competent authorities of the
Contracting State to be of a substantially similar character, provided that the amount of
the tax referred to in this paragraph shall, however, be an amount of 10% of the gross
amount of such dividends.
15. Article 24
NON-DISCRIMINATION
1. Nationals of a Contracting State shall not be subjected in the other Contracting State to
any taxation or any requirement connected therewith, which is other or more burdensome
than the taxation and connected requirements to which nationals of that other Contracting
State in the same circumstances are or may be subjected.
2. The taxation on a permanent establishment which an enterprise of a Contracting State has
in the other Contracting State shall not be less favourably levied in that other Contracting
State than the taxation levied on enterprises of that other Contracting State carrying on
the same activities.
3. Enterprises of a Contracting State, the capital of which is wholly or partly owned or
controlled, directly or indirectly, by one or more residents of the other Contracting State
shall not be subjected in the first-mentioned Contracting State to any taxation or any
requirement connected therewith which is other or more burdensome than the taxation
and connected requirements to which other similar enterprises of the first-mentioned
Contracting State are or may be subjected.
4. In this Article the term "taxation" means taxes which are the subject of this Agreement.
Article 25
MUTUAL AGREEMENT PROCEDURE
1. 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 the provisions of this Agreement,
he may, irrespective of the remedies provided by the domestic law of those States,
present his case to the competent authority of the Contracting State of which he is a
resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting
State of which he is a national. The case must be presented within 3 years from the first
notification of the action resulting in taxation not in accordance with the provisions of the
Agreement.
2. The competent authority shall endeavour, if the objection appears to it to be justified and
if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual
agreement with the competent authority of the other Contracting State, with a view to the
avoidance of taxation which is not in accordance with the Agreement. Any agreement
reached shall be implemented notwithstanding any time limits in the domestic law of the
Contracting States.
3. The competent authorities of the Contracting States shall endeavour to resolve by mutual
agreement any difficulties or doubts arising as to the interpretation or application of this
Agreement. They may also consult together for the elimination of double taxation in
cases not provided for in this Agreement.
4. The competent authorities of the Contracting States may communicate with each other
directly for the purpose of reaching an agreement in the sense of the preceding
paragraphs.
5. The competent authorities of the Contracting States may by mutual agreement settle the
mode of application of this Agreement and, especially, the requirements to which the
residents of a Contracting State shall be subjected in order to obtain, in the other
16. Contracting State, tax reliefs or exemptions on income referred to in Articles 10, 11 and
12, received from that other Contracting State.
Article 26
EXCHANGE OF INFORMATION
1. The competent authorities of the Contracting States shall exchange such information as is
necessary for carrying out the provisions of this Agreement or for the prevention of fraud
or fiscal evasion or for the administration of statutory provisions against tax avoidance in
relation to the taxes which are the subject of this Agreement. Any information so
exchanged shall be treated as secret and shall not be disclosed to any persons or
authorities other than those, including a court, concerned with the assessment and
collection, the enforcement or prosecution in respect of those taxes or the determination
of appeals in relation thereto and the persons with respect to whom the information
relates.
2. In no case shall the provisions of paragraph 1 be construed so as to impose on a
Contracting State the obligation:
(a) to carry out administrative measures at variance with the laws and administrative
practice of that or of the other Contracting State;
(b) to supply information which is not obtainable under the laws or in the normal
course of the administration of that or of the other Contracting State; or
(c) to supply information which would disclose any trade, business, industrial,
commercial or professional secret or trade process, or information, the disclosure of
which would be contrary to public policy.
Article 27
MISCELLANEOUS RULES
The provisions of this Agreement shall not be construed to restrict in any manner any exclusion,
exemption, deduction, credit, or other allowance now or hereafter accorded:
(a) by the laws of one of the Contracting States in the determination of the tax imposed by that
Contracting State; or
(b) by any other special arrangement on taxation in connection with the economic or technical
cooperation between the two Contracting States.
Article 28
DIPLOMATIC AGENTS AND CONSULAR OFFICERS
Nothing in this Agreement shall affect the fiscal privileges of diplomatic agents or consular
officers under the general rules of international law or under the provisions of special
agreements.
Article 29
ENTRY INTO FORCE
17. 1. This Agreement shall be ratified and the instruments of ratification shall be exchanged at
Seoul as soon as possible. The Agreement shall enter into force upon the exchange of
instruments of ratification.
2. This Agreement shall have effect:
(i) in respect of tax withheld at the source on amounts paid or credited on or after the
first day of January of the calendar year next following that of the entry into force
of the Agreement; and
(ii) in respect of other taxes for taxation years beginning on or after the first day of
January of the calendar year next following that of the entry into force of the
Agreement.
Article 30
TERMINATION
This Agreement shall remain in force indefinitely but either of the Contracting States may, on or
before the thirtieth day of June in any calendar year from the fifth year following that in which
the instruments of ratification have been exchanged, give to the other Contracting State, through
diplomatic channels, written notice of termination and, in such event, this Agreement shall cease
to have effect:
(a) in respect of tax withheld at the source on amounts paid or credited on or after the first day
of January in the calendar year next following that in which the notice is given; and
(b) in respect of other taxes for taxation years beginning on or after the first day of January in
the calendar year next following that in which the notice is given.
In witness whereof the undersigned, being duly authorized thereto by their respective
Governments, have signed this Agreement.
Done in duplicate at Jakarta, this tenth day of November of the year one thousand nine hundred
and eighty eight in the English language.
FOR THE GOVERNMENT OF THE
REPUBLIC OF INDONESIA
sgd
ALI ALATAS
Minister for Foreign Affairs
Republic of Indonesia
FOR THE GOVERNMENT OF THE
REPUBLIC OF KOREA
sgd
Mr. Kwang Soo Choi
Minister for Foreign Affairs
Republic of Korea
PROTOCOL
At the moment of signing the Agreement between the Government of the Republic of Indonesia
and the Government of the Republic of Korea for the Avoidance of Double Taxation and the
Prevention of Fiscal Evasion with respect to Taxes on Income, the undersigned have agreed that
the following provisions shall form an integral part of the Agreement.
18. 1. In respect of subparagraph (b) of paragraph 3 of Article 2 of the Agreement, it is
understood that the Agreement shall apply to the Korean defense tax where charged by
reference to the income tax or the corporation tax.
2. In respect of paragraph 5 of Article 11, it is understood that interest on deferred payment
sales is included in the term interest if it is in accordance with the provisions in the
domestic laws of a Contracting State.
In witness whereof, the undersigned have signed this Protocol which shall have the same force
and validity as if it were inserted word by word in the Agreement.
Done in duplicate at Jakarta, this tenth day of November of the year one thousand nine hundred
and eighty eight in the English language.
FOR THE GOVERNMENT OF THE
REPUBLIC OF INDONESIA
sgd
ALI ALATAS
Minister for Foreign Affairs
Republic of Indonesia
FOR THE GOVERNMENT OF THE
REPUBLIC OF KOREA
sgd
Mr. Kwang Soo Choi
Minister for Foreign Affairs
Republic of Korea