PRESIDENT OF THE REPUBLIC OF INDONESIA

DECISION OF THE PRESIDENT OF THE REPUBLIC OF INDONESIA 176 IN 1998

ABOUT THE PASSAGE OF APPROVAL BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA

AND THE GOVERNMENT OF THE SYRIAN ARAB REPUBLIC ON TAX EVASION

THE PRESIDENT OF THE REPUBLIC OF INDONESIA,

DRAWS: A. that in Jakarta, on 27 June 1997 the Government of the Republic of Indonesia has signed an Agreement between the Government of the Republic of Indonesia and the Government of the Arab Republic of Syria on Multiple Taxation Avoidance and the Prevention of Use of Tax upon Earnings, as a result of the negotiations between the delegates of the Government of the Republic of Indonesia and the Government of the Syrian Arab Republic;

b. that in respect of that, in accordance with the President of the Republic of Indonesia to the Chairman of the People's Representative Council Number 2826 /HK/1960 on 22 August 1960 on the Creation of agreements with Other States, it is considered necessary to validate the Agreement with the Presidential Decree.

Given: Section 4 of the paragraph (1) and Article 11 of the Basic Law of 1945;

DECIDED:

Establits: THE PRESIDENT ' S DECISION ON THE RATIFICATION OF APPROVAL BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND THE GOVERNMENT OF THE SYRIAN ARAB REPUBLIC ON MULTIPLE TAX AVOIDANCE AND THE PREVENTION OF TAX-TAX EVASION.

section 1

Passed the Agreement between the Government of the Republic of Indonesia and the Government of the Syrian Arab Republic on Multiple Taxation Avoidance and the Prevention of Revenue of Revenue, which the Republican Government has signed. Indonesia in Jakarta, on 27 June 1997, as a result of the negotiations between the delegates of the Government of the Republic of Indonesia and the Government of the Syrian Arab Republic whose copy of the original manuscripts in Indonesian, Arabic and Inggeris. attached to this Presidential Decree.

Article 2

The President ' s Decision this goes into effect on the set date.

To ...

PRESIDENT OF THE REPUBLIC OF INDONESIA

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For everyone to know, ordering the invitation of this Presidential Decree with its placement in the State Sheet of the Republic of Indonesia.

Set in Jakarta on the 29th. September 1998 THE PRESIDENT OF THE REPUBLIC OF INDONESIA

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BACHARUDDIN JUSUF HABIBIE was promulred in Jakarta on 29 September 1998 MINISTER OF STATE SECRETARY OF STATE OF THE REPUBLIC OF INDONESIA

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AKBAR TANDJUNG

SHEET OF STATE REPUBLIC OF INDONESIA IN 1998 NUMBER 167

APPROVAL BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA

AND THE GOVERNMENT OF THE SYRIAN ARAB REPUBLIC

ABOUT MULTIPLE TAX AVOIDANCE AND PREVENTION

TAX EVASION ON INCOME

THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND THE IBM REPUBLIC OF SYRIA. The government of the Syrian Arab Republic.

SUCCESSFULLY held an Agreement on multiple tax avoidance and the prevention of tax-related tax evasion.

-HAS AGREED TO BE THE FOLLOWING:

Section 1

PERSONS AND BODIES COVERED IN CONSENT

This agreement applies to persons and bodies who are residents of one or both of the Parties on the Agreement.

Article 2 TAXES COVERED IN THIS AGREEMENT

1. This agreement applies to taxes on the income imposed by each of the parties in the Agreement or the government of the region, regardless of the terms of the tax-tax bill.

2. As a tax on income or income, it is the tax on which the profits of the goods are paid. Taxes on the amount of pay or wages paid by the employers.

3. This agreement must be applied to the current taxes, namely:

a) in the case of Indonesia: income tax imposed under the Income Tax Act 1984 (Act Number 7 of the Year 1983 as has been changed); (subsequently referred to as the "Indonesian tax");

b) in terms of Syria: -income tax on income from commerce, industry, and not

trade;-income tax on wages and wages;-income tax on non-residents;-income tax on income from the treasury and the goods not motion;- levies imposed on the percentage of the taxes mentioned in

top or in other forms or tariffs; (the next is referred to as the "Syrian tax").

4. This agreement applies to any similar or similar taxes imposed after the date of the signatory of this Agreement in addition to, or as a substitute for the taxes that are now in effect. Authorized officials from both parties in the Agreement must notify each other of any important changes that occurred in their taxation laws.

Article 3 BRAKING-understanding UMUM

1. Unless the terms of the sentence must mean otherwise, the Agreement is to be defined in this Agreement: a) the term "a State of the Agreement" and "the State on the Agreement

others" means Indonesia or Syria, depending on its terms; b) the term "Indonesia" includes the territory of the Republic of Indonesia as defined

in The term "Syria" means, in the geographical sense, the territory of the Syrian Arab Republic,

including its water region, its airspace, its continental shelf, the lower layer of soil and other areas of the sea. Syria's territory, which is based on international law, Syria has rights. sovereignty to utilize and investigate natural resources, important resources and mining resources and other rights on the ocean floor and the bordering ocean and the bordering ocean;

d) the term "person /body" Including personal, corporate and any collection of people and/or bad-bad;

e) the term "citizen" means: (i) any person who has a citizenship of a party State on the Agreement; (ii) any legal entity, joint venture or fellowship whose status they acquire under the law applicable to one of the Parties to the State of the State of the United States. Consent;

f) the term "perseroan" means any legal entity or any entity for the purpose of a tax party is treated as a legal entity;

g) the term "company of a party State on the Agreement" and " the company of the The other party countries in the Agreement " each means a company that run by residents of a party State on the Agreement and a company run by the residents of the Other State on the Agreement;

h) the term "international traffic" means any transport by the seabed or aircraft performed by a company of a State on the Agreement, unless a ship or airship is solely operated between the places in the other State on the Agreement;

i) the term "authorized officer" means: -in regards to Indonesia, the Minister of Finance or his authorized deputy;-in regards to Syria, the Minister of Finance or his authorized deputy.

2. With respect to the application of the Agreement by one of the Parties to the Agreement, any term not formulated in this Agreement has the meaning in the laws of the country as long as the taxes are set forth in the Agreement. This consent, any understanding according to the taxation laws of the State, is applicable beyond the understanding given to that term by other laws of the State.

Section 4 RESIDENTS

1. For the benefit of this Agreement, the term "citizen of a State of the Agreement" means any person and body, according to the laws of the State, may be taxed in the State by its domicility, its place of residence, The place where his management is, however, on the other basis of similar nature. But in this term it does not include persons and bodies that can be taxed in the Country only on the basis of income from the sources in the State.

2. Ions in any form.

4. The provisions in verses 1 and 3 apply also to the income obtained from the non-motion of a company and to the income of the non-motion possessions used in the running of free work.

4. The provisions in verses 1 and 3 apply also to the income obtained from the non-motion of a company and to the income of the non-motion possessions used in the running of free work.

5. Deviations from the provisions of Articles 7 and 14, if persons or bodies

owns shares or ownership rights within a company, corporate society or similar institution and is therefore entitled to enjoy non-motion treasures located in a State of the Union in the Agreement and which is controlled by the the company, company, company, or agency of that type, then the revenue from the direct use of rent or use in other means of such enjoyment by the person or the body may be subject to tax in the State.

Section 7 PROFIT ENTERPRISE

1. The profit of a corporation from the State in the Agreement will only be taxed in the Country unless it runs a business in the other State on the Agreement through a fixed form of effort. If the company is running its business as referred to above, then the company's profits may be taxed in the other Country but only on the profit that comes from (a) the form of such fixed effort; (b) the sale of which the company is based on. performed in other countries of the same or similar merchandise with those sold through the form of a fixed entity; or (c) other business activities executed in other countries are similar or similar. its kind with that done through the form of a fixed effort.

2. With regard to the terms of paragraph 3, if a company of a party country on the Agreement runs an effort in the State of the Other on the Agreement through a form of fixed effort that is there, then it will be taken into account. In the event of a separate, non-production, non-production, non-production enterprise may be a separate, independent company that performs the same or similar activities in the form of a separate entity. the same or similar state, and adrapes a fully free relationship with a company that has a fixed form of effort.

3. In determining the size of a fixed form profit, a fee may be deductable for the business interests of the fixed form including the cost of the leadership and costs of the general administration issued in the country. where the fixed form of effort is or somewhere else.

4. As long as it is customary in a party country in the Agreement to set the expected profit a fixed form of effort based on a share of such profits that may be customary, the means of calculation of division The value of the company's profits on its various parts, the provisions of the paragraph (2) will not close the possibility for the State of the Parties to the Agreement in determining the tax-imposed profits of a shared share, In any case, it shall be according to the principles that are in the right hand. is contained in this Section.

5. The sheer profits derived from the purchase of goods or merchandise carried out by a fixed form of effort for the company, are not counted as the profits of the fixed form of effort.

6. For the sake of the preceding paragraphs of this section, the magnitude of the fixed-form profit remains to be determined in the same way from year to year, unless there is

a strong and sufficient reason to perform irregularations.

7. If in the number of profits included in a separately regulated income in the other sections of the Agreement, then the provisions of this section will not be affected by the provisions of this section.

8. The provisions of this section will not affect the provisions of a State of the Agreement with respect to taxation on the profits of the insurance venture.

9. Deviations from other provisions in this Agreement, a company based on a State of the Agreement which has a form of permanent business in the Agreement, the benefits of a fixed form of business. It will be subject to additional taxes on the other side of the State in connection with the legislation, but such additional taxes will not exceed 10 percent of the amount of profits after deducable income taxes and other taxes. levied on the other side of the state.

10. The provisions of paragraph 9 of this Section shall not affect the provisions contained in a Contract for the Results and Contracts of Works (or any other similar contract) related to the oil or gas sector, or other mining sectors that signed by the Government of Indonesia or the Government of Syria, parts of its government, or other state or state gas and gas companies with persons or persons who are residents of the other parties in the Agreement.

Section 8 SHIPPING AND AIRLIFT

1. The profits of a corporation from the State on the Agreement obtained from the operation of a seaplane or airship in an international traffic lane will only be taxed in the country. Such profits include profits from the use, maintenance or leasing of containers used for the transport of goods or merchandise on international traffic lines, under the terms of such activities as their nature only. Just once.

2. The provisions of paragraph 1 apply to the profits of the inclusion in a joint enterprise, a joint effort or from a representative for international operations.

3. The provisions of this section do not include the profits obtained by a company from a party country on the Agreement through a sales commission in the Other State on the Agreement, from the travel tickets of the aircraft or the ships The sea belongs to other companies.

Article 9 OF THE COMPANIES THAT HAVE

SPECIAL RELATIONS

1. If a) a company of a State of the State on Approval directly

and may not directly participate in the management, supervision or capital of a company in the other State of the Agreement, or

b) the same person or entity either directly or indirectly in the The management, supervision, or capital of a corporation from the State on the Agreement and a corporation from the other State on the Agreement,

and in both ways it is between the two companies referred to in its trading or relationship relations. The financial will be held or applied to the deviate terms of the usual applicable between companies that are completely free of each other, then any profits that are supposed to be accepted by one of the companies if those terms are not present, but are not accepted because of those terms, can be added on the company ' s profits were taxed.

2. If a party of the State of the State of the State of the State of the United States has a tax on the profits of the company, and tax and profit, it is also the profit of a corporation that is taxed in the other. In the Agreement, the Agreement and the Agreement are the profits that are supposed to be acquired by a corporation in the State of the United States, in the first called Agreement between the two companies that are fully free, the other party's State of the will be recustomization of the amount of the profits that are taxed from the Companies in other countries in the Agreement. In doing these adjustments, it is required to pay attention to the other provisions of this Agreement and if it is deemed necessary that authorized officials from the two countries consult each other.

3. The parties to the Agreement will not perform the company's operating profit as referred to in paragraph (2) if the time limit provided by the country's taxation laws is exceeded.

Article 10 DEVIDEN

1. A deviation paid by a company based on a State of the State in the Agreement to the other party's residents in the Agreement may be taxed in the other Stateovisions of paragraph (2) shall not affect the provisions of a party State on the Agreement that exclude the pension of tax imposition.

Article 20 TEACHERS AND RESEARCHERS

A person before a visit to a The parties to the Agreement are the other citizens of the State on the Agreement and on the invitation of the Government of the State on the Agreement called first or university, academies, schools, museums or other cultural institutions of the United States. Party States on the Agreement called first or through cultural exchange the official, which is in the state of the Agreement for a period of no more than two consecutive years solely for the purpose of teaching, giving lectures or conducting research at the intended institution will be exempt from the imposition of taxes in the State The parties to the agreement are paid for such activities, provided that the payment by which it is derived from outside the State at the Agreement.

Article 21 STUDENT AND INTERN

1. Payments received by the student or the intern who is a resident or immediately before visiting a State on the Agreement is a resident of another State on the Agreement and is in the State of the State. the first solely to follow education or exercise, solely for the purpose of life, education or exercise of no taxes in the first mentioned State, as long as those payments are from outside the State. That's right.

2. In connection with the grants, scholarships and rewards from work not covered in verse 1, a student or the intern mentioned in the verse

1, in addition, entitled during education or such training is provided the same exclusions, leniations or deductions, which concern the taxes imposed on the citizens of the State on the The approval that he has covered.

Article 22 OF THE OTHER INCOME

1. Portions of the IBM International Passport Agreement or IBM International Passport Agreement ("Agreement") are subject to the terms and terms of the IBM International Passport Agreement Agreement ("Agreement"), which are not governed by the terms of this Agreement, in addition to the income arising as a or management of the property that is in the State of the Other on the Agreement and also income in the form of a lottery, gift-gift and insurance premiums or reinsurance in the State called first.

2. The provisions of the paragraph (1) of this section do not apply to the income of such non-motion treasures in Section 6 (2) of this Agreement, if the recipient of such income, which is a citizen of a State in the Agreement, runs efforts in other countries in the Agreement through a fixed form of consent, or performing free work in other States of a fixed entity located there, and the rights or property of which income is made. It has an effective relationship with a fixed form of effort or a fixed place of effort. In such case, depending on the problem, the provisions of the section 7 or Section 14.

Article 23 of the Multiple Tax avoidance method

1. If a person from a party country on the Agreement earns income, in accordance with the terms of this Agreement, may be subject to tax on other States, then the State of the so-called First Must be referred to as the " The reduction of taxes on the income of the population is of the same amount as income tax paid in other countries. Nevertheless, the amount of such credit should not exceed the number of taxes in the State called first over the income calculated in accordance with the tax law and the rules of the State.

2. If, in connection with other provisions of the Agreement, the income obtained by the residents of the State on the Agreement is excluded from the taxes in the country, then the State must account for the income excluded. of taxes in the tax calculation on the income of deviders.

Article 24 NON DISCRIMINATION

1. Citizens of a State of the State in the Agreement shall not be subject to any tax or liability in respect of the imposition of taxes in the other State on the Agreement, which is discrete or more burdensome than the imposition of taxes and Party obligations, which are subject to or may be subject to the citizens of the other State of the United States under the same circumstances.

2. A tax charge on the form of a fixed entity owned by a corporation from the State of the Agreement on the Other Side of the Agreement, will not be performed in a less favorable way than the upper tax imposition. Companies that are running the same activities on the other side of the country. This provision may not be construed as requiring a party of State in the Agreement to provide the other party residents of the Agreement on a personal cut, leniation and deductions for the the importance of tax imposition based on the civil status or family responsibility as given to its own residents.

3. Companies in a State of the State on the Agreement, whose capital is partially or wholly owned or controlled either directly or indirectly, by one more resident of the other party's State on Approval, will not be taxed or any liability relating to the imposition of a tax in the State called the first of the same or more damning of the tax imposition and the intended obligations imposed or may be subject to any of the companies. others are similar in the Nation called first.

4. Except where the provisions of Section 9 paragraph 1, Section 11 paragraph 7 or Section 12 paragraph 6 apply, interest, royalty and other payments paid by the company from the State of the State on the Agreement to the citizens of the other party in the Agreement. in determining the taxable profit of such a company shall be subtracted under the same conditions if it is paid to the residents of the first called State.

Article 25 LAYOUT OF THE MUTUAL CONSENT

1. If a person or a body assumes that the actions of either party or both of the State on the Agreement results in or will result in the imposition of the tax that does not comply with this Agreement, then regardless of the ways A solution that is governed by the national laws of the respective States, he may submit the problem to the official in the State of the State in the Agreement where it is located, or if the issue arising concerning paragraph 1 Section 24, to the officials in the State of the Parties to the Agreement where it is To be a citizen. Such problems must be submitted within two years of the first notice of the action resulting in the imposition of the tax that does not comply with the provisions of this Agreement.

2. If any objection is warranted enough to be resolved and if the problem cannot be found in a satisfactory settlement, the official must attempt to resolve the matter by mutual consent. with the other State of the Union authorized in the Agreement with the intent to prevent tax imposition that is not in compliance with this Agreement.

3. Officials who are authorized by the two parties in the Agreement through a joint agreement must attempt to resolve any difficulties or doubts arising in the interpretation or application of this Agreement. It can then also consult together to prevent multiple tax imposition in terms of not being set up in the Approval.

4. Official respect of the services he provided to the State or its government will only be imposed. tax in that country.

b) However, such pension will only be taxed in the other party States on the Agreement when the person is a resident and citizen of the other State of the State.

3. The provisions of Section 15, 16 and 18 shall apply to the salary, wages and other similar rewards and respect of the pension, of the services provided in connection with the efforts executed by a State of the Agreement or the Agreement. The state government.

4. The pr