2011, No. 9465

Section 6

(1) When the Income Tax Income is Uplift or any other type of reward as referred to in Article 2 of the paragraph (1) is at the time of earnings of Uplift or any other type of reward being paid or recognized as a fee, depending on which event first occurs.

(2) Over the Income Tax as referred to in Article 2 of the paragraph (1) is required to be cut by the Contractor performing payment Uplift or other similar exchange using a proof form format cut as set forth in Annex II, which is an inseparable part of this Minister Rule.

Article 7

(1) The income of the Income Tax on the diversion of Participating Interest as referred to in Article 2 of the paragraph (2) is at the time of payment, at the time of the transfer of Participating Interest, or at the time of the release of the Participating Interest of Participating Interest by the Minister of Energy and Mineral Resources, It depends on the event that occurred earlier.

(2) Over the Income Tax as referred to in Section 2 of the paragraph (2) is required to be cut by a Contractor that accepts the transfer of Participating Interest by using the format of the cut evidence form as set forth in Annex II, which is the part not And in the event of a Contractor that accepts the transfer of Participating Interest as referred to in the paragraph (2) it is not listed as the Tax Wajib at the time of its Income Tax. referred to in paragraph (1), the owed Income Tax is required to be self-paid by Contractors who receive the transfer of Participating Interest by using the Tax Deposit Letter on behalf of the Contracting Contractor Participating Interest.

(4) In the event of a debt Income Tax is not made available by Contractors who receive a Participating Interest as referred to in paragraph (3), the owed Income Tax is required to be cut, deployed, and reported by Contractors who received the transfer of Participating Interest at the time after being listed as Wajib Tax in accordance with the taxation field.

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2011, No. 946 6

(5) In terms of diversion of Participating Interest performed indirectly and does not change the Subject Number of Taxes, Contractors who divert Participating Interest are required to provide your own Tax. Outstanding income by using the Tax Deposits Letter.

Article 8

The Income Tax as referred to in Article 6 of the paragraph (2) and/or Article 7 of the paragraph (2), paragraph (3), paragraph (4), and paragraph (5), is required to be provided to the country's coffers, as applicable with the timeframe as set forth in the Regulation of the Finance Minister governing Regarding payment, deductions, deductions, deductions, and/or tax reporting.

Article 9

(1) The income tax that has been described as referred to in Section 8 is required to be reported to:

a. The Tax Service Office of the Contractor that performs the Uplift payment or any other similar exchange is listed on the payment as referred to in Article 6 of the paragraph (2);

b. The Tax Service Office of the Contractor that accepts the transfer of Participating Interest is listed on the payment as referred to in Article 7 of the paragraph (2) and paragraph (4); and/or

c. The Tax Service Office of the Contractor where the Contracting Participating Interest is listed on the payment as referred to in Article 7 of the paragraph (3) and the paragraph (5).

(2) The specified Income Tax Reporting as referred to in paragraph (1) is performed in the term as specified in the Financial Minister Regulation which governs regarding the determination of the due date of payment, the deposit and the $4 paragraph (2) for the following additional income parts.

Article 10

(1) For the Taxpayer Income after minus the Income Tax. is a final derived from Uplift or any other return that

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2011, No. 9467

a type as referred to in Section 2 of the paragraph (1) and/or the income of a Contractor from the diversion Participating Interest as referred to in Article 2 of the paragraph (2), the Income Tax is in compliance with the regulations

(2) Income Tax Treatment against other income Contractors are not specifically regulated in this Minister's Regulation, applicable laws in the field of Income Tax. Generally applicable.

Section 11

The Income Tax Calculations as referred to in Section 2, Section 3, and Section 10 of the paragraph (1) is performed according to the example as set forth in Annex III, which is an inseparable part of this Minister's Regulation.

Article 12

(1) The Terms of Use When the Income Tax is referred to in Section 6 of the paragraph (1) and Section 7 of the paragraph (1) does not apply to the income of Uplift or any other similar exchange and income of the transfer of Participating Interest, which occurred from December 20, 2010 until shortly before the enactment of the Minister ' s Regulation This.

(2) When the Income Tax Income Tax is Uplift or other similar exchange and income from the diversion of Participating interest as referred to by paragraph (1) is on the effective date of the payment. This Minister's Rule.

(3) The provisions as referred to in Article 10 of the paragraph (1) are applied against the Income Taxpayer Income after the final Income Tax, for the income of Uplift or other rewards that type and/or earnings of a Participating Interest which received or acquired following the enactment of this Minister ' s Regulation.

Article 13

The Regulation of the Minister came into force on 1 January 2012.

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2011, No. 946 8

For everyone to know it, ordering the Minister of the Union Regulation by its placement in the News of the Republic of Indonesia.

Specified in Jakarta on 28 December 2011

MINISTER FINANCE

REPUBLIC OF INDONESIA,

AGUS D.W. MARTOWARDOJO

Reinvited in Jakarta On 28 December 2011

MINISTER FOR LAW AND HUMAN RIGHTS

REPUBLIC OF INDONESIA,

AMIR SYAMSUDIN

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2011 Written documents include the Participating Interest and Financial Quarterly Report (FQR) final quarterly agreement prior to the transfer of Participating Interest.

by using the transfer report form format Participating Interest as set forth in Appendix I, which is terest in the Bima block. Although formally the transaction is a stock diversion but the substance of the transaction is a diversion of interest (substance over form).

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2011, No. 94615

The final PPh tally owed by BUT Charlie Bima Ltd. is as follows:

PPh final = 7% x US$ 20,000.00 = US$ 1,400,000.00

(provided by BUT Charlie Bima Ltd. to the country's coffers). Gama Pty. Ltd. is not listed in Indonesia)

Next BUT Charlie Bima Ltd. will change its name to BUT Gama Bima Ltd. without the changes of NPWP.

Calculations of Article 26 of the paragraph (4) of the income tax after minus the final PPh of the diversion Participating Interest is as follows:

The earnings of the diversion Participating Interest

Issued Fees (excluding expenses-fees already returned by the Government)

=

=

US$ 20,000.00

US$ 14.400,000.00

Income taxable

PPh final

=

=

US$ 5,600,000.00

US$ 1,400,000.00

DPP PPh Section 26 paragraph (4) = US$ 4.200,000.00

PPh Section 26 of the paragraph (4) is in debt (20%xUS$4.200,000.00) US$ 840,000.00

c. Participating Interest exempted from the final PPh cuts:

In 2018, BUT Charlie Bima Ltd again sells 10% interest in the Bima block to the Regional Company (PD) Gemah Ripah in accordance with its obligations It's on a contract with a transaction value of US$ 10,000,000.00.

Over the transfer of interest it is not owed to the final PPh as long as it is done in accordance with the provisions set out in the contract of cooperation.

d. The diversion of interest with a settlement method is a certain percentage of the amount of production:

In 2018 but Gama Bima Ltd. transferred 30% interest that it had directly to BUT Tera Ltd. with a deal.

1) Paid upfront for US$ 20,000,000.00;

2) 2% per year from lifting of the contracting part oil until the end of the contract.

In 2019 the number lifting section of BUT Tera Ltd. is US$ 100,000.00

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2011, No. 946 16

The sum of the debtors owed to the diversion as follows:

Year 2018

PPh final = 7% x US$ 20,000.00 = US$ 1,400,000.00 (specified by BUT Tera Ltd. to the state coffers and BUT Tera Ltd. is mandatory. provide proof of the cut to BUT Gama Bima Ltd.)

The calculation of Article 26 of the paragraph (4) of the income taxable after minus the final PPh of the diversion Participating Interest is as follows:

Income from the diversion Participating interest

The fee has been issued (not including costs-expenses already returned by the Government)

=

=

US$ 20.000.00

US$ 14.400,000.00

Income taxable

PPh final

=

= =

US$ 5.600,000.00

US$ 1.400,000.00

DPP PPh Section 26 paragraph (4) = US$ 4.200,000.00

PPh Section 26 of the paragraph (4) is in debt (20%xUS$4.200,000.00) US$ 840,000.00

Year of 2019

Number of payments to BUT Gama Bima Ltd.

= 2% x US$ 100,000.00

= US$ 2.000,000.00

PPh final = 7% x US$ 2.000.00

= US$ 140,000.00

(provided by BUT Tera) Ltd. to the state coffers)

Calculations of Article 26 of the paragraph (4) of the income taxable after minus the final PPh of the diversion Participating Interest is as follows:

The revenue from the diversion Participating Interest

Charges that have been issued (not including those expenses already restored by the Government)

=

=

US$ 2.000.000.00

US$ 1.440,000.00

Income taxable

PPh final

=

=

US$ 560,000.00

US$ 140,000.00

DPP PPh Section 26 verse (4) = US$ 420,000.00

Article 26 of the paragraph (4) is in debt (20%x$ 420,000.00) US$ 84,000.00

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2011, No. 94617

3. An example of the exception of the Income Tax charge for the transfer of Participating Interest in an exploratory time:

In order to share the risk in Exploration, the diversion of Participating Interest does not include income which is subject to the final when meeting the criteria (cumulative) as follows:

a. does not assign all Participating Interest to its own;

b. Interest Interest has been owned by more than 3 (three) years;

c. in the workspace has been conducted explorations (there have been investment expenditures); and

d. The diversion Participating Interest is not meant to benefit.

Example:

The Alfa Inc. interest is a mobile company in the field of oil and gas mining, established in the state of X.

The Berta Inc. is a mobile company in the field of oil and gas mining, established in the state of Y.

It was announced in 2009, Alfa Inc. won the tender offer block of my duku migas. Alfa Inc. forms Alfa Duku Inc. in the country Z and lists the BUT Alfa Duku Inc. (ADI) in the Office of Tax Services Agency and Stranger People Two. ADI was signed to the Board of Petroleum and Earth Gas (BPMIGAS) in 2009 and held 100% of interest in the Block. States X, Y, and Z are countries not P3B partners.

s until 2014, ADI has spent US$ 4,000,000.00 in exploratory activities on the Duku Block.

The 2015-year anniversary of the 2015 BUT SO signed a contract for a diversion interest by 50% (fifty percent) to the Berta Duku. Inc (BDI).

This transaction has met three (three) criteria for the exception of the final PPh identification number a, the letter b, and the letter c above.

The following is an example of a transfer transaction interest of the BUT SO to BUT BDI during the period of time. Exploration is associated with risk sharing:

1) The buyer (BUT BDI) is reimbursed ADI proportionately

compensation arrangement:

BUT BDI will be reimbursed 50% (fifty percent) of the cost of the BUT BDI. ADI was US$ 2,000,000.00 (50% from US$ 4,000,000.00). Starting in 2015, the cost of exploration will be borne but ADI and BUT BDI respectively-by 50% (fifty percent).

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2011, No. 946 18

This transaction is included in the definition of Participating Interest which is not intended to benefit. Since this transaction has met 4 (4) transaction criteria in order to share the risk, then the transaction is not owed by the final.

If the BUT BDI turns out to pay US$ 3,000,000.00 to ADI for 50% (fifty percent) it is not in the final. of the total fees that the ADI has been issued so that in this case, ADI has a benefit of US$ 1,000,000.00 (US$3.000.00-US$ 2,000,000.00) then this transaction is not included in the understanding of the risk sharing and therefore Liabilities PPh final.

PPh final= 5% x US$ 3,000.00 = US$ 150,000.00

(cut off by BUT BDI, and BUT BDI is required to provide proof of the Piece to. US$ 4.200,000.00

PPh Section 26 of the paragraph (4) is in debt (20%xUS$4.200,000.00) US$ 840,000.00

b. In 2017, Charlie Ltd. transferred 30% interest in the Bima Block through the sale of 100% shares of Charlie Bima Ltd. to Gama Pty. Ltd. with a transaction value of US$ 20,000,000.00. Thus, Gama Pty. Ltd. has 30% interest in the Bima block through Charlie Bima Ltd. (SPV company).