Regulation Of The Minister Of Finance Number 256/fmd. 011/2011 2011

Original Language Title: Peraturan Menteri Keuangan Nomor 256/PMK.011/2011 Tahun 2011

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Read the untranslated law here: http://peraturan.go.id/inc/view/11e44c515e895bf09f6d313233353038.html

Microsoft Word-bn945-2011 REPUBLIC of INDONESIA No. 945, 2011 MINISTRY of FINANCE. Allocation Of Indirect Costs. Disallowed Expenses. REGULATION of the MINISTER of FINANCE of the REPUBLIC of INDONESIA NUMBER 256/FMD. 011/2011 ABOUT the LIMITATIONS of EXPENDITURE the ALLOCATION of INDIRECT COSTS HEADQUARTERS which CAN BE RETURNED in the CALCULATION for YIELD and INCOME TAX for CONTRACTORS in the SAME EMPLOYMENT CONTRACT OIL and GAS with the GRACE of GOD ALMIGHTY the MINISTER of FINANCE of the REPUBLIC of INDONESIA, Considering: that in order to implement the provisions of article 12 and paragraph (2) letter f number 3 the Government Regulation Number 79 in 2010 about the operating cost is refundable income tax Treatment and in the upstream Businesses Oil and Gas, it needs to set a regulation of the Minister of finance about the allocation of Expenditure limit on the indirect costs of the headquarters which can be Returned in the calculation For yield and income tax for the oil and Gas Contractors; Remember: 1. Law number 6 Year 1983 on general provisions and Taxation Procedures (State Gazette of the Republic of Indonesia Number 49 in 1983, an additional Sheet of the Republic of Indonesia Number 3262) as it has several times changed with Act No. 4 of 2009 (State Gazette of the Republic of Indonesia Number 62 in 2009, an additional Sheet of the Republic of Indonesia Number 4999); www.djpp.kemenkumham.go.id 2011, no. 945 2 2. Act No. 7 Year 1983 regarding income tax (State Gazette of the Republic of Indonesia Number 50 in 1983, an additional Sheet of the Republic of Indonesia Number 3263) as it has several times changed with Act No. 36 of 2008 (State Gazette of the Republic of Indonesia Year 2008 Number 133, additional sheets of the Republic of Indonesia Number 4893); 3. Government Regulation Number 79 in 2010 about the operating cost is refundable income tax Treatment and businesses Upstream Oil and Gas (State Gazette of the Republic of Indonesia year 2010 Number 139, an additional Sheet of the Republic of Indonesia Number 5173); 4. Presidential Decree Number 56/P in 2010; Decide: Define: REGULATION Of The MINISTER Of FINANCE ABOUT The ALLOCATION Of EXPENDITURE LIMIT On The INDIRECT COSTS Of The HEADQUARTERS Which CAN BE RETURNED In The CALCULATION For YIELD And INCOME TAX For The OIL And GAS CONTRACTORS. Article 1 In this ministerial regulation is: 1. Contractor Cooperation Contract oil and Gas which are hereinafter referred to as the contractor is a business entity or a business form remains assigned to conduct exploration and exploitation in the area work based on a contract of cooperation with the Implementing Agencies. 2. The Central Office is a business entity that performs the activities of funding and/or investments to support petroleum operations for affiliates including in Indonesia and providing services to support the operation of petroleum for its affiliates as well as create consolidated financial statements. 3. The implementing Agency is an agency established to do control the upstream business activities in the field of oil and Gas. 4. Petroleum Operations are activities that includes exploration, exploitation, transportation, closure and wells (plug and abandonment) and the restoration of the former quarry (site restoration) oil and natural gas. www.djpp.kemenkumham.go.id 2011, no. 5 9453. Exploration is an activity that aims to obtain information about the geological conditions to discover and obtain the estimated oil and gas reserves in the region specified. 6. The exploitation is a series of activities aiming to produce oil and gas from a specified region, which consists of the drilling and completion of wells, construction of means of transport, storage, and processing for separation and purification of oil and gas in the field as well as other activities that support it. 7. Cost of capital (capital cost) is spending done to equipment or goods that have benefits over a period of 1 (one) year pembebanannya in walking through depreciation. 8. Costs Not Modal (non capital cost) is the cost incurred in the current year operations have period benefits less than 1 (one) year, including surveys and intangible drilling cost. Article 2 the expenditure allocation of indirect costs can be restored in the headquarters of the calculation for the results and become a deduction in calculating gross income Tax Income of contractors. Article 3 (1) Expenditure allocation of indirect costs a Central Office can be restored and become a deduction gross income referred to in article 2 must satisfy the following requirements: a. issued to obtain, collect, and keep the income in accordance with the provisions of laws-invitations and directly related to Petroleum operations in the territory of the concerned Contractors working in Indonesia; b. used to support business or activities in Indonesia; c. the contractor have submitted consolidated financial statements audited Headquarters; and d. the contractor laid the basis of allocating indirect costs in the form of Headquarters: 1) to the contractor at the time of exploration, namely work and budget plan which has been approved by the implementing Bodies; www.djpp.kemenkumham.go.id 2011, no. 945 4 2) to Contractors during Exploitation, namely: a) the written consent of the method of allocation of indirect costs by Implementing Agency Headquarters, in terms of detailed studies have been performed (detailed study) by Implementing Agencies; or b) allocation method proposals indirect costs head office that has been declared complete by the implementing Agency, in terms of not done detailed studies (detailed study) by the implementing Agency. (2) in the event that the requirements referred to in paragraph (1) letter a, letter b, letter c and/or the letter d are not fulfilled by the contractor, the expenditure allocation of indirect costs head office can not be returned in the calculation for the results and not to be gross income deduction in calculating income tax. Article 4 (1) of the magnitude of the spending allocation of indirect costs head office referred to in Article 2 are set out: a. the highest 2% (two percent) of the total cost of capital spending and Costs is not a Capital during the period of Exploration in the area of work Contractors in Indonesia; b. the highest 2% (two percent) of the total cost of capital expenses and the cost of Capital is not in question during the period of Exploitation in work areas the contractor in Indonesia, with examples numbering as contained in the attachment, which is part an integral part of this regulation of the Minister. (2) Exploration Period referred to in subsection (1) letter a are calculated from the date of the contract effective cooperation up to the year of approval of the field development plan first on a work-area contractor. (3) the period of Exploitation as referred to in paragraph (1) letter b are calculated from the expiration of the Exploration as referred to in paragraph (2) until the expiration date of the contract of cooperation. (4) in terms of the magnitude of spending allocation of indirect costs Head Office approved the implementing Entity value is smaller than the quantity allocation of expenses indirect costs head office referred to in subsection (1), the magnitude of the spending allocation of indirect costs Headquarters which can be returned in the calculation for the results and be gross income deduction in the calculation of income tax for the contractor does not exceed the magnitude of expenditure that has got the approval of the implementing Agency. www.djpp.kemenkumham.go.id 2011, no. 9455 article 5 this Ministerial Regulation went into effect on January 1, 2012. In order to make everyone aware of it, ordered the enactment of this Ministerial Regulation with its placement in the news of the Republic of Indonesia. Established in Jakarta on 28 December 2011 the INDONESIAN FINANCE MINISTER AGUS MARTOWARDOJO D.W., Enacted in Jakarta on December 28, 2011 MINISTER of LAW and HUMAN RIGHTS REPUBLIC of INDONESIA, AMIR SYAMSUDDIN www.djpp.kemenkumham.go.id


2011, no. 945 6 EXAMPLES of CALCULATING the ALLOCATION of INDIRECT COSTS HEADQUARTERS which CAN BE RETURNED in the CALCULATION for YIELD and INCOME TAX for CONTRACTORS in the SAME EMPLOYMENT CONTRACT OIL and natural GAS. 1. An example of the calculation of quantity allocation of indirect costs in their Headquarters: Topaz Exploration Ltd. is a company engaged in the field of mining, oil and gas, which was established in country X. In 2011, the Topaz Ltd. won the tender offer oil and gas blocks Bima in the Java Sea. Topaz Ltd. to form Topaz Bima Ltd. in country Z and register BUT Topaz Bima Ltd. at the Tax Services Office of the governing body and Two Foreigners. Topaz Bima Ltd. signed a contract with the implementing Entities business activities Upstream Oil and Gas (oil & gas BP) in 2011. By 2015, Topaz Ltd. field development plan approval (POD) in the first block of Bhima from BP Oil and gas. The following data on the allocation of indirect costs at Headquarters BUT Topaz Bima Ltd. during the period of exploration (2011 to 2015): year% allocation of indirect costs Allocation Spending Total Headquarters Costs not directly the head office 2011 2.00% $100,000 $2,000 50,000.00 50,000.00 2012 4.00% $180,000 $7,200 50,000.00 50,000.00 2013 1.00% $250,000 $2,500 50,000.00 50,000.00 2014 3.00% $200,000 $6,000 50,000.00 50,000.00 2015 2.00% $220,000 $4,400 50,000.00 50,000.00 $950,000 50,000.00 Amount $22,100, 000.00 a. the inspection done before approval of the POD : By 2013 there is the assignment of inspection over BUT Topaz Bima Ltd. for the tax year. Based on the results of the inspection, there was no correction over total spending, then the magnitude of the allocation of indirect costs Headquarters which can be a deduction on gross income in the year 2012 by BUT the ATTACHMENT of the INDONESIAN FINANCE MINISTER REGULATION NUMBER 254/FMD. 011/2011 ABOUT the LIMITATIONS of EXPENDITURE the ALLOCATION of INDIRECT COSTS HEADQUARTERS which CAN BE RETURNED in the CALCULATION for YIELD and INCOME TAX for CONTRACTORS in the SAME EMPLOYMENT CONTRACT OIL and natural GAS. www.djpp.kemenkumham.go.id 2011, no. 9457 Topaz Bima Ltd is $7.200.000 2,000 (4% X 180.000.000 US $2,000). Despite the magnitude of the allocation of indirect costs Headquarters which can be a deduction on gross income in the year 2012 (US $7.200.000) more than 2%, i.e. 4%, by a team of reviewers was not done the correction, since the limitations of a maximum of 2% for a period of Exploration rather than per year but 2% of the total expenditure during the period of exploration (adjustment is done on the last year of the period of Exploration). b. the examination carried out in a POD: in 2016, there is the assignment of inspection over BUT Topaz Bima Ltd. for the tax year of 2015. Calculating the allocation of indirect costs Headquarters which can be a deduction on gross income by 2015 are as follows: allocation of indirect costs, according to the headquarters of the KKKS = $22,100, 000.00 maximum limit the imposition of the allocation of indirect costs Headquarters during his exploration of the 2% X $950,000 = $19,000 50,000.00 50,000.00 From the above calculation, then the magnitude of the allocation of indirect costs Headquarters which can be a deduction on gross income during the period of maximum limit of exploration is , i.e., the US $19,000, 000.00. Adjustments (correction) the allocation of indirect costs head office in 2015 for the whole period of exploration is as follows: allocation of indirect costs, according to the headquarters of the KKKS = $22,100, 000.00 maximum limit the imposition of the allocation of indirect costs Headquarters during their Exploration = ($19,000, 000.00) Correction $3,100, 000.00 and so the magnitude of the allocation of indirect costs head office in 2015 is for: allocation of indirect costs, according to the headquarters of the KKKS = $4,400, 000.00 correction the allocation of indirect costs Headquarters = ($3,100, 000.00) allocation of indirect costs a Central Office can charged = $1,300, 000.00 www.djpp.kemenkumham.go.id 2011, No. 947 8 following the summary imposition of allocation of indirect costs at Headquarters BUT Topaz Bima Ltd. during the period of exploration (2011 to 2015): year% indirect Cost allocation of Headquarters according to the inspection results Total Expenses KKKS realization of allocation of indirect costs Allocation Spending Total Headquarters Costs not directly the head office 2011 2% $100,000 $2,000 50,000.00 50,000.00 $100,000 50,000.00 $2,000 50,000.00 $180,000 50,000.00 2012 4% $7,200 $180,000 50,000.00 50,000.00 $7,200 50,000.00 $250,000 50,000.00 2013 1% $2,500 $250,000 50,000.00 50,000.00 $2,500 50,000.00 $200,000 50,000.00 2014 3% $6,000 $200,000 50,000.00 $6,000 50,000.00 50,000.00 2015 2% $220,000 $4,400 50,000.00 50,000.00 $220,000 50,000.00 $1,300 50,000.00 $950,000 50,000.00 Amount $22,100, $950,000 $19,000, 000.00 000.00, 000.00 c. In terms of the percentage of indirect costs head office before the POD has exceeded 2% of the total expenditure during the period of Exploration: in terms of the magnitude of the percentage allocation of indirect costs Headquarters BUT Topaz Ltd. in the above example, in 2014 is by 5%, so the magnitude of the allocation of indirect costs Headquarters for 2014 becomes of US 10, 000.00 and the total allocation of indirect costs are charged to the Headquarters by BUT Topaz Ltd. during the period of exploration into the US $26,100, 000.00, then the magnitude of the allocation of indirect costs Headquarters which can be a deduction on gross income during the period of maximum limits is Exploration, namely US $19,000, 000.00. Adjustments (correction) the allocation of indirect costs head office in 2015 for the whole period of exploration is as follows: allocation of indirect costs, according to the headquarters of the KKKS = $26,100, 000.00 maximum limit the imposition of the allocation of indirect costs Headquarters during their Exploration = ($19,000, 000.00) Correction = $7,100, 000.00 and so the magnitude of the allocation of indirect costs head office in 2015 is for: allocation of indirect costs, according to the headquarters of the KKKS = $4,400, 000.00 correction the allocation of indirect costs Headquarters = ($7,100, 000.00) allocation of indirect costs a Central Office can charged = ($2,700, 000.00) www.djpp.kemenkumham.go.id 2011, no. 9459 following the summary imposition of allocation of indirect costs at Headquarters BUT Topaz Bima Ltd. during the period of exploration (2011 to 2015): year% indirect Cost allocation of Headquarters according to the inspection results Total Expenses KKKS realization of allocation of indirect costs Allocation Spending Total Headquarters Costs not directly the head office 2011 2% $100,000 $2,000 50,000.00 50,000.00 $100,000 50,000.00 $2,000 50,000.00 $180,000 50,000.00 2012 4% $7,200 $180,000 50,000.00 50,000.00 $7,200 50,000.00 $250,000 50,000.00 2013 1% $2,500 $250,000 50,000.00 50,000.00 $2,500 50,000.00 $200,000 50,000.00 2014 5% 10, $200,000 10, 000.00 000.00, 000.00 2015 2% $220,000 $4,400 50,000.00 $220,000 50,000.00 50,000.00 $ (2,700, 000.00) total $950,000 $26,100 50,000.00 50,000.00 $950,000 50,000.00 $19,000 50,000.00 d. in case there are correction total expenditures during the period of exploration: in terms of total spending BUT Topaz Ltd. in the example above, based on the results of the examination, there is a correction in 2012 of US $30,000, 000.00 and so the total spending in 2012 from the beginning of US $180,000, 000.00 being the US $150,000, 000.00, then the magnitude of the allocation of indirect costs Headquarters which can be a deduction on gross income during the period of Exploration is as follows 2012: the year the allocation of indirect costs Headquarters which can be a deduction on gross income in the year 2012:4% X US $150,000, 000.00 = US $6,000, 000.00 for the year 2012 is done so that the correction over the magnitude of the allocation of indirect costs allocation of Central Office headquarters of the indirect costs according to the KKKS = $7,200, 000.00 indirect cost allocation of Central Office based on inspection results = ($6,000, 000.00) Correction = $1,200, 000.00 2015 Calculating the allocation of indirect costs Headquarters which can be a deduction on gross income by 2015 are as follows : www.djpp.kemenkumham.go.id 2011, no. 945 10 allocation of indirect costs, according to the headquarters of the KKKS = $22,100, 000.00 maximum limit the imposition of the allocation of indirect costs Headquarters during his exploration of the 2% X ($950,000, 000.00 – US $30,000, 000.00) = $18,400, 000.00 From the above calculation, then the magnitude of the allocation of indirect costs Headquarters which can be a deduction on gross income during the period of maximum limits is Exploration, namely US $18,400, 000.00. Adjustments (correction) the allocation of indirect costs head office in 2015 for the whole period of exploration is as follows: allocation of indirect costs, according to the headquarters of the KKKS = $22,100, 000.00 maximum limit the imposition of the allocation of indirect costs Headquarters during their Exploration = ($18,400, 000.00) Correction = $3.700, 000.00 Correction allocation of indirect costs head office in 2012 based on inspection results = ($ 1,200, 000.00) allocation of indirect costs Headquarters by 2015 based on the inspection results = $2,500, 000.00 and so the magnitude of the allocation of indirect costs in the year 2015 was rate: allocation of indirect costs, according to the headquarters of the KKKS = $4,400, 000.00 correction the allocation of indirect costs Headquarters = ($2,500, 000.00) allocation of indirect costs that can be charged to the Headquarters = $1,900, 000.00 in the following summary of the imposition of the allocation of indirect costs at Headquarters BUT Topaz Bima Ltd. during the period of exploration (2011 to 2015): www.djpp.kemenkumham.go.id


2011, no. 94511 Year% indirect Cost allocation of Headquarters according to the inspection results Total Expenses KKKS realization of allocation of indirect costs Allocation Spending Total Headquarters Costs not directly the head office 2011 2% $100,000 $2,000 50,000.00 50,000.00 $100,000 50,000.00 $2,000 50,000.00 $180,000 50,000.00 2012 4% $7,200 $150,000 50,000.00 50,000.00 $6,000 50,000.00 $250,000 50,000.00 2013 1% $2,500 $250,000 50,000.00 50,000.00 $2,500 50,000.00 $200,000 50,000.00 2014 3% $6,000 $200,000 50,000.00 50,000.00 $6,000 50,000.00 $220,000 50,000.00 2015 2% $4,400 $220,000 50,000.00 50,000.00 $1,900 50,000.00 $950,000 50,000.00 Amount $22,100, $920,000 $18,400, 000.00 000.00, 000.00 e. In terms of the percentage of indirect costs head office is smaller than 2% during the period Exploration: the following data on the allocation of indirect costs at Headquarters BUT Topaz Bima Ltd. during the period of exploration (2011 to 2015): year% allocation of indirect costs Total Headquarters Expenditures allocation of indirect Cost Realization Headquarters 2011 1.8% $100,000 $1,800 50,000.00 50,000.00 2012 1.7% $180,000 $3,060 50,000.00 50,000.00 2013 2.0% $250,000 $5,000 50,000.00 50,000.00 2014 2.2% $200,000 $4,400 50,000.00 50,000.00 2015 1.9% $220,000 $4,180 50,000.00 50,000.00 $950,000 50,000.00 Amount $18,440, 000.00 maximum limit the imposition of the allocation of indirect costs Headquarters during the period of Exploration : 2% X $950,000 = $19,000 50,000.00 50,000.00 From the above calculation, then the magnitude of the allocation of indirect costs Headquarters which can be a deduction on gross income during the period of Exploration is US $18,040, 000.00 so that by 2015 there are no adjustments (correction) upon the allocation of indirect costs head office. 2. Calculation example of quantity allocation of indirect costs in their Headquarters of exploitation: To the contractor at the time of exploitation, in filing the allocation of indirect costs, the Central Office must deliver: a. written consent methods of allocation of indirect costs by Implementing Agency Headquarters, in terms of detailed studies have been performed (detailed study) by Implementing Agencies; or www.djpp.kemenkumham.go.id 2011, no. 945 12 b. proposal method of allocation of indirect costs head office that has been declared complete by the implementing Agency, in terms of not done detailed studies (detailed study) by the implementing Agency. In the event that the above requirements are not met, then the contractor is not entitled to charge indirect costs allocation of Central Office. a. the period of Exploitation after entry into force of this regulation of the Minister: by 2015, the taxpayer has submitted a work plan and budget (the Work Program and Budget/WP&B) for the year 2016, along with a proposal for the method of allocation of indirect costs headquarters and has obtained written consent of BP Oil & gas 2% since the year 2016 and beyond unless there is a change in the method of allocation of indirect costs head office. In 2016 BUT Topaz Ltd started production. The following data on the allocation of indirect costs at Headquarters BUT Topaz Bima Ltd. during the period of Exploitation (2016 until 2020): year% allocation of indirect costs Total Headquarters Expenditures allocation of indirect costs of realization of the headquarters of the 2016 2% $100,000 $2,000 50,000.00 50,000.00 2017 4% $180,000 $7,200 50,000.00 50,000.00 2018 1% $250,000 $2,500 50,000.00 50,000.00 2019 3% $200,000 $6,000 50,000.00 50,000.00 2020 2% $220,000 $4,400 50,000.00 50,000.00 $950,000 50,000.00 Amount $22,100, 000.00 magnitude of allocation of indirect costs head office can be a deduction by the gross income BUT Topaz Bima Ltd. are as follows : www.djpp.kemenkumham.go.id 2011, no. 94513 Years BP Oil and gas Approvals Examiner KKKS *)% allocation of indirect costs Total Headquarters Expenditures (realized) the allocation of indirect costs head office% Total Spending approved (approval) the allocation of indirect costs allocation of headquarters of the indirect costs of the headquarters of 2016 2% $100,000 $2,000 50,000.00 50,000.00 2.00% $100,000, 000.00 $2,000 $2,000, 000, 000.00. 00 2017 4% $180,000 $7,200 50,000.00 50,000.00 2.00% $180,000, 000.00 $3,600 $3,600, 000, 000.00. 00 2018 1% $250,000 $2,500 50,000.00 50,000.00 1.00% $250,000, 000.00 $2,500 $2,500, 000, 000.00. 00 2019 3% $200,000 $6,000 50,000.00 50,000.00 2.00% $200,000, 000.00 $4,000 $4,000, 000, 000.00. 00 2020 2% $220,000 $4,400 50,000.00 50,000.00 2.00% $220,000, 000.00 $4,400 $4,400, 000, 000.00. 00 Description: *) in case there is a correction of the total expenses (cost of correction), the size of the allocation of indirect costs head office can be a deduction is gross income amounting to a maximum of 2% of the total expenditure after a correction based on the results of the inspection. b. Exploitation Period before entry into force of this regulation of the Minister: Zircon Ltd. is a company engaged in the field of mining, oil and gas, which was established in country X. In 2001, Zircon Ltd. won the tender offer oil and gas blocks Bima in the Java Sea. Zircon Ltd. form the Zircon Bima Ltd. in country Z and register BUT Zircon Bima Ltd. at the Tax Services Office of the governing body and Two Foreigners. BUT Zircon Bima Ltd. signed a contract with BP Oil and natural gas in 2001. In 2010, BUT Zircon Ltd. started production. The following data on the allocation of indirect costs Headquarters BUT Zircon Bima Ltd. during the period of Exploitation (year 2010 to 2015): year% allocation of indirect costs Total Headquarters Expenditures allocation of indirect costs of realization of Central Office 2010 1.80% $200,000 $3,600 50,000.00 50,000.00 2011 2.00% $220,000, 000.00 $2.00% 2012 4,400,000.00 $250,000 $5,000 50,000.00 www.djpp.kemenkumham.go.id 50,000.00 2011, no. 945 14 2013 2.00% $300,000 $6,000 50,000.00 50,000.00 2014 2.00% $350,000 $7,000 50,000.00 50,000.00 2015 2.00% $300,000 $6,000 50,000.00 50,000.00 in 2011 , Taxpayers filed WP&B for the year 2012, and approved BP Oil and gas without notes. In 2012, Taxpayers filed WP&B for 2013, BP Oil and gas and has been approved by the records for the allocation of indirect costs to Headquarters by 2013 will be tailored to the results of a detailed study conducted BP Oil and gas. After a detailed study of BP Oil & gas in 2014 approved the allocation of the magnitude of the indirect costs of the headquarters of 1.8%, and effective as of 2013. The magnitude of the allocation of indirect costs head office can be a deduction by the gross income BUT Zircon Bima Ltd. is as follows: Years BP Oil and gas Approvals Examiner KKKS) *% allocation of indirect costs Total Headquarters Expenditures (realized) the allocation of indirect costs head office% Total Spending approved (approval) the allocation of indirect costs allocation of Headquarters cost not directly the head office 2010 1.80% $200,000 $3,600 50,000.00 50,000.00 $200,000 50,000.00 1.80% $3,600 $3,600, 000, 000.00. 00 2011 2.00% $220,000, 000.00 $2.00% 4,400,000.00 $220,000 50,000.00 $4,400 50,000.00 $4,400, 000. 00 2012 2.00% $250,000 50,000.00 $5,000 50,000.00 $250,000 50,000.00 3% $5,000 $5,000, 000, 000.00. 00 am 2013 2.00% $300,000 50,000.00 $6,000 50,000.00 $300,000 50,000.00 1.80% $5,400 $5,400, 000, 000.00. 2014 00-2.00% $350,000 50,000.00 $7,000 50,000.00 $350,000 50,000.00 1.80% $6,300 $6,300, 000, 000.00. 00 2015 2.00% $300,000 50,000.00 $6,000 50,000.00 $300,000 50,000.00 1.80% $5,400 $5,400, 000, 000.00. 00 Description: *) in case there is a correction of the total expenses (cost of correction), the size of the allocation of indirect costs head office can be a deduction is gross income amounted to a maximum of 2% (for the year 2011 to 2012) or appropriate written consent of BP Oil (namely 1.8% from 2013) of total expenditure after a correction based on the results of the inspection. INDONESIAN FINANCE MINISTER AGUS MARTOWARDOJO D.W., www.djpp.kemenkumham.go.id