PRESIDENT OF THE REPUBLIC OF INDONESIA

DECISION OF PRESIDENT REPBULIK INDONESIA NUMBER 161 1998

ABOUT PASSAGE OF APPROVAL BETWEEN REPUBLICAN GOVERNMENT

INDONESIA AND THE GOVERNMENT OF THE REPUBLIC OF UZBEKISTAN ON TAX AVOIDANCE DOUBLE AND PREVENTION

TAX ON INCOME (VENTURE PROFIT)

PRESIDENT OF THE REPUBLIC OF INDONESIA,

DRAWS: A. that in Jakarta, on August 26, 1996 the Government of the Republic of Indonesia has signed an Agreement between the Government of the Republic of Indonesia and the Government of the Republic of Uzbekistan on Multiple Taxation Avoidance and the Prevention of Use of Top Tax. Earnings, as a result of the negotiations between the delegates of the Government of the Republic of Indonesia and the Government of the Republic of Uzbekistan;

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

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

DECIDE

Establits: APPROVAL OF THE AGREEMENT BETWEEN THE GOVERNMENTS OF THE REPUBLIC OF INDONESIA AND THE GOVERNMENT OF THE REPUBLIC OF UZBEKISTAN ON MULTIPLE TAX AVOIDANCE AND THE PREVENTION OF TAX EVASION OF INCOME (VENTURE PROFITS).

section 1

Pass the Agreement between the Government of the Republic of Indonesia and the Government of the Republic of Uzbekistan on the Avoidance Of Multiple Taxation and the Prevention of Income Taxes, which has been signed. The Government of the Republic of Indonesia in Jakarta, on 26 August 1996, as a result of the negotiations between the delegates of the Government of the Republic of Indonesia and the Government of the Republic of Uzbekistan which copies of the original manuscripts in Indonesian, Uzbekistan and the English as attached to this Presidential Decree.

Article 2

This President ' s decision comes into effect on a set date.

To ...

PRESIDENT OF THE REPUBLIC OF INDONESIA

-2-

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

Specised in Jakarta on September 18, 1998 PRESIDENT OF THE REPUBLIC OF INDONESIA,

ttd.

BACHARUDDIN YUSUF HABIBIE

Reundrased in Jakarta on September 18, 1998

MINISTER OF STATE SECRETARY OF STATE OF REPUBLIC OF INDONESIA,

ttd.

AKBAR TANDJUNG

SHEET OF STATE REPUBLIC OF INDONESIA IN 1998 NUMBER 154

APPROVAL BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA

AND THE GOVERNMENT OF THE REPUBLIC OF UZBEKISTAN

ABOUT MULTIPLE TAX AVOIDANCE AND THE PREVENTION OF

THE INCOME TAX

THE REPUBLICAN GOVERNMENT Indonesia and the Government of the Republic of Uzbekistan SUCCESSFULLY held an Agreement on the avoidance of multiple taxation and the prevention of tax-related income (venture profits), with the intent to increase economic cooperation. between the two countries;

HAS AGREED AS FOLLOWS:

Section 1 OF PEOPLE 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 State on the Agreement or its local government regardless of the terms of the tax-tax bill.

2. As a result, they are considered a tax-tax on all income or income, including taxes on the profits earned by moving objects or from moving them into the market. Unmoving objects, and taxes on all the wages and salaries paid for by companies.

3. This agreement is applied to the current taxes, in particular: (a) regarding the Republic of Indonesia: the income tax imposed under the 1984 Income Tax Act (Law Number 7 of 1983 as amended. changed); (subsequently referred to as "Indonesian tax"); (b) regarding the Republic of Uzbekistan:

i) tax on companies, associations and organizations; and

ii) taxes on the private income of the population of the Republic of Uzbekistan, foreigners and not the population of other countries; (Furthermore, referred to as the "Uzbek tax").

4. This agreement also applies to any similar taxes or to the same nature imposed after the signing date of the Persetujaun in addition to, or as a substitute for the taxes that are now in effect. Officials who are authorized by the State of the Parties to the Agreement will notify each other of each other regarding any important changes that have occurred in their taxation laws.

Article 3 OF THE COMMON NOTIONS

1. Unless the terms of the sentence must mean otherwise, the Agreement is to be defined in this Agreement: (a) The term "Indonesia" covers the territory of the Republic of Indonesia as defined in its laws; (b) The term "Uzbekistan" means the Republic of Uzbekistan in the geographical sense covering the land region, water and air in which the Republic of Indonesia is the Republic of Uzbekistan. Uzbekistan has the rights of sovereignty of jurisdiction including the rights to administer the layers of land and natural resources according to international law and the Act of the Republic of Uzbekistan; (c) the terms "of the terms of the Agreement" and " Other States of the Union (s). Approval " means Indonesia or Uzbekistan, depending on The terms of the sentence; (d) The term "person/body" includes a person, the company and any group of persons and/or the body; (e) the term "perseroan" means any legal entity or fellowship, venture cooperation, or other entity. treated according to the Code of Negar party on the Agreement where the company is granted status as a legal entity for the purpose of the tax; (f) the term "enterprise of a State of the Agreement" and "the State of the Agreement". other parties to 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; (g) istilan "international traffic" means any transport by sea boat or air aircraft performed by a company of a party of the State on the Agreement, unless the ship or aircraft is solely operated between the places in the other State of the Persepurpose; (h) the term " the official authority "means" Indonesia is the Minister of Finance or its authorized deputy, and in Uzbekistan is the Chairman of the State Tax Committee or its authorized representative ' (i) the term "citizen" means:

i) any person who has citizenship from a State of the State on the Agreement;

ii) any legal entity, joint effort and the fellowship whose status they acquired under the law applies to any of the Parties to the Agreement.

2. With respect to the application of the Agreement by one of the party States on the Agreement on any terms 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 agreement, unless of the hubugan the sentence should be interpreted.

Article 4 RESIDENTS

1. For the benefit of this Agreement, the term "citizen of a party of the State"

Agreement " means any person and body, in which the laws of the State may be taxed in that country by domicile, place of residence, place of establishment, place of management, or on other grounds. Same thing. But the term does not include people and the tax-owed bodies in the country based on the only reason that it gains income from the sources in the country.

2. If a person according to the terms of the paragraph (1) becomes a resident of both the Parties to the Agreement, then its status will be determined as follows: (A) he shall be considered a resident of the State where he has a fixed place which is available to him; if he has a permanent residence available in both countries, he will be considered a resident of the State where it is. More closely related personal and economic relationships (core interests); (b) if the country where the center of its interests is not determined, or if he does not have a permanent residence available to him in the one of the countries, then he would be regarded as a resident of the State where he normally resides; (c) If he had a place of habit of sitting on either side of the state in the Agreement or at all not in any of those countries, he would be considered a citizen of the State of the Agreement or not at all. one of these countries, then he is considered a citizen of the State on the Agreement where it is a citizen; (d) if each of the Parties on the Agreement considers it a citizen or not a member of the State of the State of the State of the United States. Consent regards him as a citizen, then authorized officials of the second. The parties to the Agreement will resolve the issue by mutual consent.

3. When the provisions of the paragraph (1), a body be a resident of both the Parties to the Agreement, then the officials of the two countries will solve the problem by mutual consent.

Article 5 FIXED BUSINESS FORM

1. For the benefit of this Agreement the term "permanent form" means a place of fixed enterprise where all or part of the business of a company from a party country to the Agreement is run on the other side of the other Agreement.

2. The term "fixed form form" includes: (a) a management position; (b) a branch; (c) an office; (d) a plant; (e) a workshop; (f) a farm or a farm; (g) a mine, an oil or gas well, a Excavation of resources or execration of natural resources, a bridge for a working ship or ship.

3. The term "fixed form form" also includes: (a) a building, a construction, an assembly project or an installation project

or the surveillance activities that are related to the project, but only if the building, project or activities take place for a period of more than 6 months; (b) the granting of services including consulting services by a company performed by the company through its employees or others who are employed by the company for that purpose, but only if such activities are ongoing (for the same project or the relevant one) in a Country in the United States. A period of time, which is greater than 3 months in the twelve month period.

4. Deviating from the previous provisions of this Section, the term "fixed form form" is deemed to be not included: (a) the use of the facility solely with the intent to store or exhibit the company's goods or merchandise; (b) the business of a company's goods or merchandise solely with mean to be saved or displayed; (c) the business of a company's inventory of goods or merchandise solely with the intent to be treated by another company; (d) the business of a business place remains solely with the intent to purchase of goods or merchandise or to collect information for the purposes of the company; (e) the business of a business place remains solely with the intent of advertising purposes, or to provide an outstatement; (f) the business of a business place remains solely with the intent of running. Other activities that are in preparation or support for the company; (g) the business of a business place remain solely with the intent to perform a combination of such activities mentioned on a sub-verse (a) up to the sub-paragraph (f), along the the result of the merger of all such activities is in preparation

5.

5. Deviations from the provisions of paragraph (1) and (2), if persons or body, except for the free acting agent as applicable (7), act on a State of the State in the Agreement on behalf of a company based in the State of the State of the State of the State of the United States. other in the Agreement, then the company is considered to have a fixed form in the first mentioned State for the activities performed by the person or body, if it has and is usual in the first called Country. Authorized to sign a contract on behalf of the company, Unless the activity is limited to what hangs is in the verse (4), which is, however, done through a fixed venture place, it is not a form of effort to remain in accordance with the terms of the verse;

6. An insurance company from the State of the State on the Agreement, except with respect to the reinsurance, will be deemed to have a fixed form of business in the State on the Agreement if it is picking up premiums in other areas of the country. That or bear the risk of being there through an employee, or through a representative who is not an agent acting as free as it is in verse (7).

7. A company from a party country in the Agreement will not be considered to have a form of a fixed entity in the other State of the Agreement solely because it runs a business in the other State through the Realtor, the general commissioner, or any other agent that acts freely, as long as the person or body is acting in the framework of activities

A common effort. However, when the agent's activities are meant entirely or almost entirely for the company or its corporate allies, it is not considered an agent to act freely in the sense of this verse.

8. If one of the parties of the State of the State in the State of the State in the Agreement shall be established, either through a fixed form or one another, then it will not be self-established. That one of the companies is a fixed form of effort than the other.

Article 6 EARNINGS OF NON-MOVING OBJECTS

1. The income of a person from the State of the State on the Approval of the non-motion (income obtained from agriculture or forestry) who is on the other side of the Agreement can be taxed in. The other negars.

2. In this Agreement, the term "non-motion object" has a meaning in accordance with the laws of the Party of the Parties to the Agreement on which the object is located. The term includes the following elements of non-moving objects, livestock and equipment used in agricultural and forestry endeavour, all manner of fisheries, rights to which the provisions of the law are common. Possession of land, the right to collect unmoving objects, as well as the right to fixed or unfixed payment of service for work, or the right to work on mineral content, other sources of natural wealth, ship of the sea, and the aircraft is not considered an unmoving object.

3. "The right to collect the results" used in this section means the right to use all the time or other people's items and earn income from that right.

4. The provisions of the paragraph (1) apply also to the income obtained from the use directly, from the lease, or from the use in other ways of the non-moving object.

5. The provisions in verses (1) and (3) apply also to the income obtained from the non-moving objects of the company and to the income of non-movable objects used in the running of free work.

Article 7 OF THE VENTURE PROFIT

1. A profit from a party country in the Agreement will only be taxed in that country unless the company runs a business in another state through a fixed form of effort. If the company is running its business as intended above, then the company's profits may be taxed in other countries but only on the profit that comes from: (a) the form of such a fixed effort;

(b) other country ' s sales of the same or similar goods or similar merchandise with those sold through the form of such fixed business; or (c) other business activities executed in that other State of the United States the same or similar type with that done through the fixed form of effort.

2. With regard to the provisions of the paragraph (3), if the company of a party country on the Agreement runs an effort in the other State of the State of the State of the United States, then it will be counted as a form profit. A fixed term is a separate company, a separate entity, and a free act that performs the same or similar activities, under the same circumstances. or similar, and hold a fully free relationship with the company that has a fixed form form of it.

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 the general administrative costs incurred in the country. The form of a fixed effort is or somewhere else. Such reductions are not permitted in terms of the payments made by the form of a fixed business to the head office or other offices of its head office (other than the replacement of the cost that is actually issued). Royalty, fees or other similar payments due to the use of patent or other rights, or of a commission, for certain services performed or for management, or except in terms of banking business, in interest of loans. It's given to a fixed form. Not to be counted as a fixed-form profit is the amount charged by the form of a fixed effort to the head office or other offices belonging to its head office (in addition to the reimbursed cost reimbursed) in the form of a fixed amount of money. Royalty, fees or other similar payments due to the use of patent or other rights, or of a commission, for certain services performed or for management, or, except in terms of banking efforts, are interest on loans. which is given to its head office or other office belongs to its head office.

4. As long as it is a business in one of the Parties to the Agreement, to set the magnitude of the profit that can be considered to be derived from a form of effort by determining the profits of the various parts of the company's share of the whole. The company's profits and its parts, then the provisions of the paragraph (2) of this section will not cover the possibility for the State of the Union to determine the extent of the income tax on which the partition is commonly used, but the way the split must be so that the result will be according to the principles contained in this Section.

5. For the application of the preceding verses, the value of the fixed-form profit remains to be determined in the same way from year to year, if there is sufficient reason and sufficient reason to deviate.

5. For the application of the preceding verses, the value of the fixed-form profit remains to be determined in the same way from year to year, unless there is sufficient reason and sufficient reason to deviate.

6. If in the amount of revenue including the portion of the revenue set in its own terms in the Agreement, then the provisions of this Agreement, then the provisions of this Agreement.

will not be affected by the provisions of this section.

Article 8 OF THE INTERNATIONAL TRANSPORT

1. The profits obtained by a party of State on this Agreement from the operation of naval and uair vessels on international traffic will only be taxed by the party's state.

2. The provisions of paragraph (1) apply to: (a) the profits obtained from the lease (including based on barebot) ships or aircrafts operated on an internationoal traffic course that is at any time only; and (b) the following: benefit from the use, maintenance or leasing of containers (including trailers and equipment related to container-container transport), where the advantage is complementary or disordered in relation to The benefits referred to in verse (1).

3. The provisions of paragraph (1) and paragraph (2) apply to the profits of the participation in a joint company (together with mutual funds), a joint venture or from a representative for international operations.

Article 9 COMPANIES THAT HAVE SPECIAL RELATIONSHIPS

1. If: (a) a company of a party State on the Agreement either directly or indirectly participating in the management, supervision or capital of a company in the other State of the Agreement, or (b) the same person or body either directly or indirectly participate in the management, supervision or capital of a company of one of the Parties to the Agreement and a corporation from the Other State on the Agreement and in both matters. the two companies referred to in its trade relationship or its financial relationship was held or applied the deviable terms of the same applies between companies that are completely free of each other, then any profits that are supposed to be accepted by one of the companies if the terms are not present, but not The acceptance of such terms, can be added to the company's profits and tax.

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, the Agreement, the Agreement, the Agreement, the Agreement, the Agreement, the Agreement, the Agreement, the Agreement, the Agreement, the Agreement, the Agreement, the Agreement, the Agreement, the Agreement, the Agreement, the Agreement will be recustomization of the amount of the profits that are taxed from the Companies in other countries in the country are 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 may not perform the company's profit as referred to in paragraph (2) if the time limit provided by the taxation laws of each country is exceeded.

Article 10 DIVIDEND

1. The dividend paid by a company based on a State of the State in the Agreement to the other party residents of the Agreement may be taxed in the other Country.

2. However, it can also be taxed in the State on the Agreement where the retailer paid the dividends a place and in accordance with the laws of the country, but if the recipient of the dividend is the owner of the stock who enjoy that dividend and he can be taxed in connection with that dividend in the other State on Approval, then the tax imposed should not exceed 10 percent of the gross amount of the dividend paid.

3. The term "dividend" as used in this section means the income of any stock, or other rights that are not letters of debt, entitled to profit sharing, nor any other income from the rights of the company. State taxation laws in which the companies that share that dividend are based, in the imposition of their taxes are required equal to the earnings of the shares.

4. The provisions of verse (1) and (2) shall not apply if the owner of the stock enjoys the dividend, which is the resident of a party State on the Agreement, in which the companies that pay the dividends are based, through a form A fixed effort, or running a free work with a place of equal and shareholding stock that produces dividends it has an effective relationship with the form of a ttap effort or a fixed place of effort. In such case, depending on the problem, the provisions of Article 7 or Section 14.

5. If a company is a citizen of a State on the Agreement, then the State of the Agreement, then the other State on the Agreement, may not be charged with any of the dividends paid by the company, unless it is a party of the State of the State of the United States. If the dividend is paid to the residents of the other population, or if it is the expulsion of the shares which results in an effective relationship with the form of a fixed or fixed business place in the other country, also may not charge tax on unshared profits. {\cf1 \cf1 \f1 \f1 \f1 \f1 \f1 \f1 \f1 \f1 \f1 \f1 Deviations from the rest of the year. This Agreement does not apply to the IBM International Agreement for IBM International Agreement for IBM International Agreement for IBM International Agreement for IBM International Agreement for IBM International Agreement for IBM International Agreement for IBM International Agreement for IBM International Agreement for IBM International Agreement for IBM International Agreement for IBM International Agreement for IBM International Agreement for IBM International Agreement The other would be based on the legislation, but the extra tax would not have cost 10 percent of the profits after being reduced by income tax and other taxes on the calls imposed on the other countries.

7. The provisions of the paragraph (6) of this section will not affect the provisions contained in any contract for the outcome or contract of the work (or contract

other similar) concerning the petroleum and gas sector or other mining sectors approved by the Government of Indonesia, its government agencies, oil and gas companies belong to the country, or other bodies that Will the other party's citizens in the Agreement.

Article 11 BUNGA

1. Flowers from a Negar party on Approval and paid to the other party residents of the Agreement may be taxed in the other party States at the Agreement.

2. But if the recipient (the lender who enjoys the flower), then shall be the tax on which the recipient (s) of the country is in the state of the country. The other party's population in the Agreement, the imposed package will not exceed 10 percent of the gross interest rate.

3. The term "flower" used in this section means the income of all types of debt bills, whether or not in particular the income of the State of the Treasury papers and the bonds or the bonds. The letters of debt, including the premiums and gifts tied to the valuables, the bonds and the letters of the debt. Sanctions fines due to late payments will not be considered as interest for the purposes of this Article.

4. The provisions of verse (1) and verse (2) shall not apply if the loan repellation which enjoys the flower is both at a party in the Agreement, conducting business activities in the other State on the Agreement where the flower is located. It comes through a form of permanent effort that is in the same, or running a free work in another country through a place of permanent business that is there, and the debt bill that produces it has an effective relationship with the A fixed form of business or a place to keep it. In such case, depending on the problem, the provisions of Article 7 or Section 14.

5. A flower is considered to be of a State of the Approval if it is the State itself, the government of the country, or the inhabitants of the country. But if a person or body is paying for it, regardless of whether it be a member of the State of the State in the Persetjuan or not, it has a fixed form or a place of effort to remain in a State of the Union in which a man is. It is considered to be from the State of the Parties to the Agreement where the form of a fixed effort or place of effort is located.

6. If for reasons of a special relationship between a flower and an owner who enjoys a flower or between the two with someone or another body, with regard to the magnitude of the bill, the amount of interest that the interest is, the amount of interest is paid. Exceed the number of people who enjoy bynga in case of no such special relationship, then the provisions of this section will apply only to the number of approved consconsants. In such case, the sum of the provisions of this Section shall apply only to such approved amounts. In such case, the quantity in excess of such payments will remain taxed in accordance with the laws of each of the Parties at the Agreement, with regard to the other provisions in this Agreement.

Section 12 ROYALTIES

1. The royalty of the yanb is derived from the State on the Agreement and paid to the residents of another State of the Parties in the Agreement may be taxed in the other party, if the occupation is the owner of the right to enjoy the The royalty is on the ground.

2. But they shall also be taxed in the state of the country, which is in the way of the law, which is in the law of the country: but when they are the holders of the right, then the tax, and the tax, shall be in the law. It does not exceed 10% of the gross amount of the royalties.

3. The term "royalty" as referred to in this section means any kind of payment of any form received due to use, or the right to use, or the sale of any literary copyright, art or scientific work, work, or any other means of use or use of the Cloud Service. including movie theaters, or movies or tape or video recordings used for radio or television broadcast, any patent, trademark, design or model, plan, secret formula or manner of processing or due to use or right to using industrial equipment, trade or science, or for information about experience in the field of industry, trade or science.

4. The provisions of the paragraph (1) and the paragraph (2) do not apply, if the parties that have the right to enjoy, who are the residents of a State of the State in the Agreement, running an effort in the State of the Other in the Agreement where the royalties are derived, through a form of permanent effort that resides there, or does a free work in the other country through a place of fixed effort, and the right or object that produces those royalties has an effective relationship with a fixed form of effort, Or a fixed place. In such case the provisions of Article 7 or Section 14 shall apply.

5. Royalties may be considered to be from the State on the Agreement if the payment is the State itself, the local government, or the inhabitants of the country. However, if a person or body is paying the royalties, regardless of whether he is a resident of the State of the Pym in the Agreement or not, has a fixed form or a place to remain in a State of the Union in the Agreement where it is. The obligation to pay royalties arise And the roiyalties are either a fixed or fixed form of effort or a fixed ussaha place, so the royalties are considered to be from the State where the fixed form or business place is located.

6. If there is a special relationship between the person and the owner of the right who enjoys or between them and other persons, regarding the use of the rights or the information that results in the payment, the amount of royalties paid. it exceeds the amount should be agreed upon by the payer and the owner of the right if no special relationship, then the provisions of this section will only apply to the last called number. In such case, the quantity in excess of such payments will remain taxed in accordance with the laws of each of the Parties at the Agreement with regard to the other provisions in this Agreement.

7. The provisions of this section do not apply if the primary or incorrect goal is

One primary purpose of a person in interest with the procurement or submission of rights resulting in the payment of the royalties to benefit from this Section by means of procurement or submission.

Article 13 ADVANTAGE FROM THE TRANSFER OF THE OBJECT

1. The benefits that the residents of a party state on the Approval of an unmoving object, as referred to in Section 6 and located in the other State of the Agreement, may be taxed in the other State of the State. That's right.

2. Advantage of a moving object transfer that is a part of the wealth of a fixed entity owned by the company of a party State on the Agreement on the Other State on the Agreement or from moving objects is part of a fixed business place available to the residents of a State on the Agreement on the Other State of the Agreement for the purpose of free work, including the benefit of a fixed-form transfer. It's a private, or a company, or a fixed business. taxed in another State.

3. The benefits of a citizen's population at the approval of a ship's transfer or airship operate on an international traffic line or a moving object that becomes part of the operation of the ship or aircraft. will only be taxed in the Country.

4. The advantage of the transfer of other objects, except those referred to in the preceding verses, will only be taxed in the State in the Agreement where the person/body that transfers the object is located.

Article 14 of the Free Work

1. Income acquired by the residents of a State on the Agreement with respect to professional services or other free work will only be taxed in the Country except under the following circumstances, then the income is the result of such income. may be taxed in the State of the Other on the Agreement:

(a) if he has a fixed business place which is available regularly for him to run the activities in the other State on Approval, in this case only The amount of income that comes from the fixed-place business can be taxed in. The party states to Persetujun; or

(b) he is in the other State of the Agreement during a period or time beyond 90 days in the month of two months.

2. The term "professional services" primarily includes tenacity in the fields of science, literature, art, education, or education, as well as the free work done by the doctors, as well as the work of the doctors, the work of the doctors, the work of the doctors, the work of the doctors, the work of the doctors engineering experts, jurists, dentists, architects and accountants.

Article 15 WORK IN WORKING RELATIONSHIPS

1. With regard to the provisions of Article 16, 18, 19, and 21 salaries, wages and other similar rewards obtained by the citizens of a party.

in the Agreement due to the work in the working relationship, only the taxes are in the State, unless the work is done in the other State of the Agreement. In that case, the reward received from the intended job may be taxed in the other party's country.

2. Deviation from the provisions of the paragraph (1), the reward received or acquired by the people of a party State on the Agreement of the work performed in the State of the Other in the Agreement, will only be taxed in the State of the State of the State of the United States. other on the Agreement, will only be taxed in the State of the so-called first if: (a) the recipient of the reward is in any other country in a period of time or time not exceeding 183 days in 12 months; and (b) the reward paid by, or on behalf of the employers, not the citizens of the country. other such; and

3. Deviating from the previous provisions in this Section, the rewards obtained due to the work done on board a seaplane or airship operated in an international traffic lane by a company and a country. parties to the Agreement will only be taxed in the country.

Article 16 REWARDS DIRECTORS

The directors and other similar payments are obtained by the citizens of the State on Approval in its position as a member the board of directors of a newspaper or any similar lainn organ of the company which in other countries in the Agreement may be taxed in the other countries.

Article 17 ARTISTS AND ATHLETES

1. Deviations from the provisions of Articles 14 and 15, income earned by residents from the State on the Agreement as an artist, film, radio or television or as an athlete, of his personal activities in a State of the State Others on the Agreement may be taxed in any other country.

2. If the income in respect of personal activities performed by the artist or athlete is accepted not by the artist or the athlete himself but by another person or body, deviates from the provisions of Article 17, 14 dn 15, then Such income can be taxed in the State on the Approval of the action-executable artist or an athlete.

3. Deviation from the provisions of paragraph (1) and (2), cannot be applied to the income obtained from the activities performed by the artist or the athlete in the State on the Agreement, if the visit to that country is fully-made. is financed by the general funds of either party or both the State on the Agreement or local local government. In this case the income can only be taxed in the state at the artist's approval of the dimna or the athlete.

Article 18 PENSION AND PERIODICAL PAYMENTS

1. Pension paid to residents of a party State on

Agreement sourced from other party States on the Agreement and the periodic payments paid to the residents of the above source will only be taxed in the other party States.

2. Isitilah "periodic payment" means a certain amount paid periodically at a given time or a time to be determined due to the mandatory payment of the payment in return of the amount of money or that it is entitled to the payment of the amount of the payment. assessed with money.

Article 19 OF THE GOVERNMENT OFFICIALS

1. (a) The patches, aside from the pension, paid by the State on the Agreement or the government of the region to a person in connection with the services provided to the State or to the government of the region, will only be imposed. Taxes in the country. (b) However, the payment will only be taxed in the other State on the Agreement if the services are given in Negar the other party and the person is the resident of the State who:

i) is a citizen of the State of the State of the State of the United States. The country; or ii) does not become a resident of the State solely for

the intent of providing such services. 2. (a) The pension paid by, or from a fund set up by a

the party of the party on the Agreement or its local government to the person in respect of its services to the State or its part or The state government will only be taxed in the 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 in Articles 15, 16 and 18 will be applied in exchange for the rewards and pensions of the services provided in connection with activities executed by a State on the Agreement, or the government of the region.

Article 20 STUDENTS

Repayment received by the student or holder who is a resident or immediately before visiting a State on the Agreement is a resident of the other Negar party in the Agreement and is in the State of the State of the State of the United States. the first mention solely to follow education or exercise, which is accepted solely for the purpose of life, education or exercise is not taxed in the first mentioned Negar, as long as the payments are from the source outside of the country.

Article 21 GURU

A before visits to one of the Parties at the destination are the other party citizens on the Agreement and at the invitation of the Government of the Parties to the Agreement called first or university, academy, school, museum or cultural institution others from the State on the Agreement called first or through The official cultural exchange program, which is in the State of the Accords for a period of no more than two years in a row for the purpose of teaching or giving lectures at the institution is meant to be liberated.

of the tax imposition in the State on that Agreement for payment for such activities, if the payment by which it is obtained is from outside the State on that Agreement.

Article 22 OF THE OTHER INCOME

1. Other types of income from the State of the State on the Approval of any source that are not included in the previous sections of the Agreement, are only taxed in Negar terebut.

2. The provisions of paragraph (1) of this Section may not apply to the income of non-movable objects, if such an income recipient is a member of the State on the Agreement, running a business in the other State of the Union ("Agreement"). Consent through the form of a fixed entity located there, or carrying out free work through a fixed place of business, and the right to an object with respect to which the income is paid has an effective relationship with the form. A fixed or fixed business place. In such case, depending on the problem, the provisions of Section 7 or Section 14.

3. The provisions of paragraph (1) and (2), the income types of the party's population on the Agreement not covered in the preceding Articles in this Agreement, and from other parties in the Agreement may also be taxed. In another country, it is.

Article 23 MULTIPLE TAX EVASION

1. If a resident of a party country on the Agreement earns an income (venture profit) in accordance with the provisions of this Agreement, it may be taxed in the State of the Other on the Agreement, then the State of the so-called First Must Increase the amount of income tax paid in other countries as a reduction in the income tax of the concerned population. However, the deduction should not exceed the portion of the income tax (profits) calculated before the reduction is given, which is after the amount of income (profits) taxed in the other country.

2. If in accordance with the provisions of this Agreement, the income obtained by the people of the one Nation in the Agreement is exempt from the charge of the tax in the country, then the country is in charge of the amount of tax. The income concerned, must account for the release of the freed.

3. For the purposes of applying paragraph (1) and (2) in this section, the income income acquired by the one party person on the Agreement which is subject to tax on the State of the Parties on the Agreement in accordance with this Agreement, shall be deemed to be derived. from the sources from other parties to the Agreement.

4. If the number of taxes released or reduced in accordance with the specific provisions in the provision of an incentive under the laws of the State of the State on the Agreement has been deemed paid in the State of the Parties to the Agreement, then the tax. Such exempts can be deductable from owed taxes on the other State of the State on Approval.

Section 24 NON DISCRIMINATION

1. Citizens of a State of the State on the Agreement are subject to a tax or liability in respect of the tax imposition in the other State on the Agreement, which is different or more important than the tax imposition and the 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. The tax imposition of a fixed entity which is milled by a corporation from the State on the Agreement on the other State of the State, should not be carried out in a less favorable way than the above tax imposition. Companies that are running the same activities on the other side of the country. This provision shall not be construed as requiring a State of the Parties to the Agreement to grant the inhabitants of the State of the Other to the Approval of a prihurricane, a sweat-leniation and a reduction-reduction for the benefit of the other. tax imposition based on the civil status or responsibility of the family as it is gered to its own residents.

3. Except for the provisions of Section 9 of the paragraph (1), Section 11 (6) or applicable, interest, royalty, and expenses-expenses paid by the company of a State on the Agreement to the United States or other party countries in the Agreement. determining the taxable profit of a company shall be deductable in the same condition that it is paid to the inhabitants of the first-placed State.

4. A Company in a State of the State on the Agreement, whose capital it is partially or wholly owned or controlled either directly or indirectly by one or more residents of the other party States on the Agreement, will not be taxed or any obligation relating to the imposition of a tax in a country called first or more incriminating on the tax imposition and the obligations referred to or may be subject to any of the companies. ; its similar design in the State called first.

5. The provisions of verse (3) will not affect the provisions of the one-State taxation laws on the Agreement intended to deal with transactions that have the aim of being tax.

6. "The term" taxation " In this section is the taxes as referred to in the Agreement.

Article 25 LAYOUT AGREEMENT TOGETHER

1. If a person or person or entity considers the actions of one or both of the States on the Agreement resulting in the imposition of the tax that is not in accordance with the Agreement, then regardless of the means of the dispersal set by the national laws of each Country, then he may submit the problem to the official in the State of the State on the Agreement where it is located, or if the issue arising concerning the paragraph (1) Psal 24 to the official Authorities in the State of the State on the Agreement where he was a resident. Such a problem.

haru is moved to the next two years from the first notice of actions that result in the imposition of an undue claim to the provisions of this Agreement.

2. The officials who are authorized must attempt, if the object's objection is reasonable enough to be resolved and unable to find a satisfactory settlement, to resolve the matter by mutual consent. Officials who are authorized by the other State of the Parties to the Situation, In Order To Prevent The Imposition Of Taxes That Are Not In Compliance With The Agreement.

3. Officials who are authorized by the two countries on the joint Peretujun must attempt to resolve any recurrency or doubt arising in the interpretation or application of the Persephone. They can also consult together to injure multiple tax imposition in the rights not governed in this Agreement.

4. Officials who are authorized by the two parties in the Agreement may be directly related to each other in order to agree to the agreement as they were in the preceding verses. The parties authorized, through consultation, will develop a joint consent procedure covered in this Section.

Article 26 EXCHANGE INFOMRATION

1. Authorized officials from both parties to the Agreement may exchange the required infomation to perform the provisions of this Agreement or to perform the country's national laws on the State of the State. The approval of the taxes included in the Agreement, as long as the charge of taxes according to the State of the State in question is not tentatively related to the Agreement. Especially in order to prevent embezzlement or tax smuggling. Any infomration received by a party state in the Agreement must be kept secret with the same fig as if the information is considered a secret in his home country, then the normation is only expressed to someone. or other (including courts and administrative bodies) in interest in the assignment or tax, execution or prosecution, or the determination of the decision regarding the taxes. which are included in this Agreement. Such persons or persons may only provide such information for the purpose above, but may also disclose the information in a public trial or in the making of the court decisions.

2. As well as the provisions of the paragraph (1) it cannot be construed in such a way that it imposes to the Negaara the party on the Agreement of obligation to:

(a) carrying out the administrative actions of the party. with applicable law or administrative practice in Negar party

on Approval;

(b) provides an infomration that may not be obtained under the law or in the administration practice prevalent in the Country or in the other party States on the Agreement; (c) provide information that reveals any confidential information in the fields of commerce, business, industry, commerce or expertise, or other trade or information governance that is to be contrary to the wisdom of the State.

Article 27 of the OFFICIAL DIPLOMATIC AND CONSULAR

This agreement will not affect Privileges in the fiscal fields of diplomatic and consular members under the common law of international law or based on the provisions of a special agreement.

Article 28 EXPIRES

Each of the parties in the Agreement will inform each other of the diplomatic path concerning the resolution of the procedures required by law to enforce this Agreement. This agreement will begin in effect on the date of the full notice of the parties and will begin to apply: (a) regarding the tax deduced on the income source, for the income that

acquired on the first day of January of the next taxable year after the enactment of this Approval;

(b) regarding the other tax on income for the tax years that begin on and after the first hi of January the following calendar year after the effective year of this Agreement.

Article 29 Termination of the Agreement

This agreement is valid until terminated by one of the countries Party to Pesedestination. Each of the parties in the Agreement may terminate this Agreement, through diplomatic channels, by providing notice of the end of the Agreement at least six months before the end of the year of the taxable. After the five-year term since the Agreement. In such case, this Agreement does not apply to the following: (a) regarding the tax deduced on the income source, for the income that

obtained on or after 1 January of the next taxable year after the year of notice The end of the Agreement is granted.

(b) regarding other taxes on income, for the tax years beginning on or after 1 January of the next tawim year after the year of notice the Agreement has been granted. As evidence of the signatories below, it has been authorized authorized, it has signed this Agreement.

CREATED in Jakarta, on 26 Agusuts a thousand nine hundred ninety-six in Indonesian, Uzbekistan and the United Kingdom. All three manuscripts have the same legal power. In terms of the most recent difference in the interpretation of Indonesian and Uzbekistan, the English dlam script will be used.

For the Government for the Government of the Republic of Indonesia Republic of Uzbekistan

ttd. Oh, no.