Indonesia - Tax Court Ruling on Beneficial Ownership of Interest on Bonds Issued by Dutch Special Purpose Vehicle
- F. Karyadi
- Derivatives & Financial Instruments, 2010 (Volume 12), No 6
- 25 November 2010
A decision by Indonesia’s Tax Court has denied the application of the 0% withholding tax rate on interest as provided under the Indonesia–Netherlands income tax treaty. The determination of the beneficial owner of the income was central to the Court’s ruling.