Emerging Markets Rates and Currencies Handbook

Tax Summary – Indonesia Indonesia W/H Tax • 20% WHT or lower (subject to implementing regulation) • Under certain tax treaties typically 10%, with further reduction possible on AW58country by country basis • 20%WHT or lower (subject to implementing regulation) • Under certain tax treaties typically 10%, with further reduction possible on country by country basis • Exempt for certain countries if paid to a bank but linked to a government loan agreement or paid to specific financial institutions/banks • Interest paid to a resident company is subject to 15% WHT, which is creditable for the receiving company • N/A • Dividends paid from a resident sub to non resident parent: 20%WHT, unless treaty in place then typically 10- 15% • Dividends paid from a resident to a individual tax payer is 0% provided such dividend is invested in Indonesia for a certain period of • time (subject to implementing regulation) • Dividends paid from a resident to corporate tax payer is 0% (without any Condition) Deductibility of interests • Generally deductible, unless D/E > 4x (excluding certain industries) • FI’s and Infrastructure = not applicable • Mining and Oil & Gas industries carry special rules • Transfer pricing rules apply • N/A • N/A Deductibility of FX losses • FX losses are considered as Deductible expense while an FX gain is considered as taxable income, with the requirement FX recognition applied consistently Other Taxes/Duties • Stamp duty is nominal and payable as a fixed amount • N/A • N/A Comments • N/A • N/A • N/A • N/A • N/A Note: Citigroup Inc. and any of its affiliates do not provide accounting, tax, or legal advice. Please seek advice from a relevant licensed advisor Source: Relevant legislation, publicly available sources Country Tax Deductibility and Considerations Inter-Co Debt Offshore Derivatives Equities Bank Loans Offshore Local Borrowing