PRESIDENT OF THE REPUBLIC OF INDONESIA

DECISION OF THE PRESIDENT OF THE REPUBLIC OF INDONESIA 157 IN 1998

ABOUT THE PASSAGE OF APPROVAL BETWEEN THE GOVERNMENT OF THE REPUBLIC

INDONESIA AND THE MONGOLIAN GOVERNMENT ON MULTIPLE TAX AVOIDANCE AND

TAX EVASION

PRESIDENT OF THE REPUBLIC OF INDONESIA,

DRAWS: A. that in Ulan Bator, Mongolia, on July 2, 1996 the Government of the Republic of Indonesia has signed an Agreement between the Government of the Republic of Indonesia and the Government of Mongolia on Multiple Taxation Avoidance and the Prevention of Use of Top Tax Earnings, as a result of the negotiations between the governments of the Government of the Republic of Indonesia and the Government of Mongolia;

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 validate the Agreement with the President's Decision;

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

DECIDED:

Set: THE PRESIDENT ' S DECISION ON THE RATIFICATION OF APPROVAL BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND THE GOVERNMENT OF MONGOLIA 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 Mongolia on Multiple Taxation Avoidance and the Prevention of Income Tax on Income, which the Government of the Republic of Indonesia has signed Ulan Bator, Mongolia, on July 2, 1996, as a result of the negotiations between the delegates of the Government of the Republic of Indonesia and the Government of Mongolia whose copy of the original manuscripts in Indonesian, Mongolian and Inggeris as attached on this Presidential Decree.

Article 2

This President ' s decision comes into effect on the set date. In order to ...

PRESIDENT OF THE REPUBLIC OF INDONESIA

-2-

For everyone to know it, order the invitation of this Presidential Decree with its placement in the Gazette of the Republic of Indonesia.

Set in Jakarta On September 18, 1998 THE PRESIDENT OF THE REPUBLIC OF INDONESIA,

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BACHARUDDIN JUSUF HABIBIE

PROMULRED IN JAKARTA ON SEPTEMBER 18, 1998 THE MINISTER OF STATE SECRETARY OF STATE OF THE REPUBLIC OF INDONESIA

ttd.

AKBAR TANDJUNG

SHEET OF STATE REPUBLIC OF INDONESIA IN 1998 NUMBER 150

AGREEMENT BETWEEN

GOVERNMENT OF THE REPUBLIC OF INDONESIA AND

GOVERNMENT OF MONGOLIA REGARDING

DOUBLE TAX AVOIDANCE AND TAX EVASION

ON INCOME

The Government of the Republic of Indonesia and The government of Mongolia SUCCESSFULLY held an Agreement on multiple tax avoidance and the prevention of tax-related tax-related tax evasion has agreed to the following:

Section 1 of the person or entity included in this Agreement

This agreement applies to persons or persons who are residents of one or both of the parties in the Agreement.

Article 2 TAXES COVERED IN THIS AGREEMENT

1. This agreement applies to taxes on the income imposed by each of the respective States in the Agreement or the state or local government, regardless of the way the tax-tax will be.

2. For all income, tax, tax, tax, tax, tax, or tax. for the total number of wages or wages paid by the company.

3. This agreement will apply to the current taxes, as:

a) as long as Indonesia:

The income tax imposed under the Act Number 7 of 1983 which remains updated;

(subsequently referred to as " Indonesian tax).

b) along about Mongolia:

1) the personal income tax;

2) the taxable income tax;

(subsequently referred to as " Mongolian tax)

4. This Agreement shall apply to any similar taxes or in the same nature imposed after the date of signing this Agreement in addition to, or in lieu of, the current taxes that are in effect. is mentioned in paragraph 3. Officials in charge of

The two parties in the Agreement will notify each other of any important changes that occurred in their taxation laws in the period of time after the change.

Article 3 GENERAL UNDERSTANDING

1. Unless the terms of the sentence must mean otherwise, the Agreement is to be defined in this Agreement:

a) The term of the State on the Agreement and the State of the Other on the Agreement means the Republic of Indonesia or Mongolia depending on its terms;

b) The term Indonesia covers the territory of the Republic of Indonesia as Defined in the laws and regions bordering on which the Republic of Indonesia has the rights of sovereignty or jurisdiction under the terms of the United Nations Convention on the Law of the Sea of 1982;

c) the term Mongolian in the geographical sense means the region of Mongolia and any region where the tax laws Mongolia is in force as far as Mongolia has implemented in those areas, in accordance with international law, the rights of sovereignty to manage its natural wealth;

d) the term person or body includes personal, perseroan and any body;

e) the term perseroan means any legal entity or any entity that for the purpose of the tax is treated as a legal entity;

f) the term of the company of a State on the Agreement and the company of the State of the Union other on the Agreement means in a row a company that is run by residents of a party state on the Agreement and a company run by the residents of the other party States on the Agreement;

g) the term citizen means:

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

(ii) any legal entity, fellowship and association whose status they acquired under applicable law applies to any of the parties. on the Agreement;

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

(i) the term authorized official means

(i) in Indonesia the Minister of Finance or his authorized deputy;

(ii) in Mongolia the Finance Minister or his authorized deputy.

2. With respect to the application of this Agreement by one of the Parties to the Agreement, any terms not formulated have the meaning in the laws of the Country as long as the taxes are regulated

in this Agreement, unless the terms of the sentence must mean another.

Article 4 RESIDENTS

1. For the benefit of this Agreement, the terms of the population of a party state in the Agreement mean any person or body, by which the laws of the State may be taxed in the State by virtue of its domisilism, the place of residence, The seat of the head office, the seat of its management or the other criteria is similar.

2. If a person is determined to be a resident of both the parties in the Agreement, then the status will be determined as follows:

a) he will be considered a resident of the State where he has a permanent residence available to him; if he has a permanent residence available in both Countries, he will be considered a resident of the State where there is a Closer personal and economic relations (principal interests-interests);

b) if the State where the center of its interests is not determined, or if it does nform of effort, then the flower shall be deemed to be from the State of the Parties at the Agreement where the form of effort remains or The place is still it.

7. If there is a reason for a special relationship between a flower and a lender who enjoys a flower or a person or another by paying attention to the debt of the debt that produces the flower, the amount of interest that is in the interest of a person or another person is paid more than the amount that is supposed to be approved between the payer and the lender who enjoys the interest in the event that a special relationship does not exist, then the provisions of this section will apply only to the last known amount. 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.

Article 12 ROYALTY

1. Royalties originating from the State on the Agreement and paid to the residents of another State on the Agreement may be taxed in the other State.

2. However, such royalty may also be taxed in the State on the Agreement where the royalties come from and in accordance with the laws of the country, but if the recipient of the royalty is the owner of the right to enjoy the royalties, then the tax. The charge will not exceed 10 percent of the gross amount of the royalties.

3. The term royalty as used in this section means any kind of payment by any form that is in return for use, or the right to use, any copyright upon written work, artwork or work in the field. science (including movie theaters, movies or tape for radio or television broadcasts), patents, trademarks, patterns or models, designs, formulas or methods of undisclosed processing, use or right to use industrial equipment tools, trade or science, or information in the field of industry, or equipment trade research, or information for industrial research, trade or science research.

4. The provisions of paragraph 1 and paragraph 2 do not apply, if the party with the right to enjoy the royalty, which is the resident of a State on the Agreement, running an effort in the State of the Other on the Agreement on which the royalties are derived, through a form of a fixed entity that resides there, or does a free work on the other side of the State through a fixed place that is there, and the right or property that produces those royalties has an effective relationship with: a) the form of a fixed or fixed place, or with b) the activities of an effort called previously on Section 7 of the 1 letter c). In such case the provisions of Article 7 or Section 14 shall

applies depending on the problem.

5. Royalties may be considered to be from the State of the Parties to the Approval if the payment is the State itself, the constitutional portion, local government, or the population of the State. However, if a person or body is paying the royalties, regardless of whether he is a member of a State on the Agreement or not, has a fixed or fixed form of business or a fixed place in a State of the Agreement on which the Agreement is located. The payment obligations arise, and the payment becomes a fixed or fixed form of a fixed or fixed place, then the royalties are considered to be from the State where the fixed or fixed-place form is located.

6. If for the reason of the existence of a special relationship between the payer and the owner of the right who enjoys or between other people or other bodies, with regard to the use of the right, or the information that gives rise to the taxpayer, the amount of royalties. paid more than the amount that the payer and the owner of the right should agree with if not such a 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.

Article 13 THE ADVANTAGE OF THE TRANSFER OF THE TREASURE

1. The benefit of a party's population in the consent of the transfer of the non-motion, as referred to in Article 6 and located on the State of the Parties to the Agreement, may be taxed in the other State.

2. Advantage of the transfer of a property that is a part of the wealth of a fixed entity owned by the company of a State of the State on the Agreement on the Other State on the Agreement or from the property of the motion part of a fixed place which is available to the residents of a State on the Agreement on the other State of the State in the Agreement for the purpose of free work, including the benefit of the transfer of the fixed form of the fixed entity (its own or with the entire company) or a fixed place, can be taxed in the State The other party.

3. The advantage of the transfer of ships or aircraft operated on international traffic lines, or the property related to the operation of the ship or airship, will only be taxed in the country.

4. The advantage of the transfer of other treasures, except those mentioned in verses 1 and 3, will only be taxed in the State on the Agreement where the person or body that transfers the property is based.

Article 14 of the work FREE

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 in some conditions, i.e. where the income is may also be taxed in other countries; or

a) if he has a fixed place in other States to exercise his activities; such income may be taxed in other States of the Union. That income is considered to be of such a fixed place.

b) if he is He has a fixed place which is available regularly for him to perform in the other State for a time or a period of 91 days a year; then the income of the other. could be taxed in another State.

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

Article 15 WORK IN THE WORKING RELATIONSHIP

1. With regard to the provisions of Articles 16, 18 and 19, salaries, wages and other similar rewards obtained by the people of a State in the Agreement due to the work done in the working relationship, will only be taxed in the That country, unless such work is done in the State of the Parties on Approval. In that case, the reward received from the intended job may be taxed in the other party's country.

2. Deviations from the provisions of paragraph 1, the rewards obtained by the people of a party State on the Agreement from the work done in the State of the Agreement, will only be taxed in the State of the first term if: a) the recipient of a person in the other State of the United States at any time or

A period of not exceeding 91 days in a taxable year; and b) the reward paid by, or on behalf of, the non-worker

represents. Other People's Countries; and c) those rewards do not be the burden of a fixed or fixed form of effort that

is owned by the employers of the other State. 3. Deviate fState itself, the tightness of it,

The government of the region, or the population of the State. However, if a person or body is paying the interest, regardless of whether he is a member of a State on the Agreement or not, it has a fixed or fixed form of business or a fixed place in a State of the Parties on the Agreement in which relationship The debt that is subject to the payment of the interest has been made, and the interest paid to be the burden of a fixed or fixed t to the citizens of the other State of the State are in the same state.

2. A tax charge for the form of a fixed entity owned by a corporation from one of the parties to the Agreement on the other State of the Agreement, will not be performed in a less favorable way than the imposition of the IBM International Agreement. tax on companies that

running the same activities on the other party's State. This provision cannot be construed as requiring a State of the State in the Agreement to provide to the other citizens of the State on the Approval of a family cut, leniation and any reduction. based on civil status or family burden for the purpose of tax imposition as provided to its own residents.

3. Except as to the extent that the provisions of Section 9 paragraph 1, Section 11 paragraph 7 or Section 12 paragraph 6, interest, royalty, and other expenses paid by the company of a State on the Agreement to the people of the Other State on the Agreement. Approval, in order to calculate the taxable income of the company, will be curated by the same requirement as if it was paid to the first-called resident of the State.

4. A Company in a State of the State on the Agreement, whose capital is partially or wholly owned or controlled directly or indirectly by the residents of the other party States on the Agreement, will not be taxed or any liability. with respect to tax imposition in a country called first or more damning than the imposition of the taxes and the obligations referred to or may be subject to other similar companies in the country. The country called first.

5. In this section referred to as tax is the taxes covered in this Agreement.

Article 25 LAYOUT OF MUTUAL CONSENT

1. If one 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 is not in compliance with this Agreement, then regardless of the manner of the settlement set up by the national laws of each Country, then he may submit the issue to the authorized officer of the State on the Agreement where it is located, or if the issue arising concerning Article 24 of the paragraph 1 to officials authorized in the State of the State on the Agreement where it became Citizens. Such problems must be submitted within three 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, and if he is unable to find a satisfactory settlement, the official will attempt to resolve the matter by mutual consent with the authority of the State of the State. Other parties to the Agreement, in order to avoid the imposition of taxes that are not in compliance with this Agreement.

3. Authorized officials from both parties to the Agreement will attempt to resolve through a joint agreement of any difficulty or doubt arising out of the interpretation or application of this Agreement. They can also consult together to prevent multiple tax imposition in terms of not being set up in this Agreement.

3. Officials who are authorized by both parties to the Agreement may be directly related to each other in order to achieve approval as referred to in the preceding paragraphs.

Section 26 EXCHANGE INFORMATION

1. Authorized officials from both parties to the Agreement shall exchange the necessary information to carry out the provisions of this Agreement or to carry out the country's national laws. each regarding the taxes covered in the Agreement, as long as the charge of the tax according to the laws of the State in question does not conflict with this Agreement. The exchange of information is not limited by the provisions of Article 1. Any information received by a party in the Agreement will be kept confidential in the same manner as if the information was obtained under the laws of the State of the Parties to that Agreement and only may disclosed to persons or officials (including courts and administrative bodies) in interest in the designation or billing of the tax, exercise of law or prosecution, or in the decision of any objection. with the taxes covered in this Agreement. The person or body or the official should only provide that information for the intent above. They may disclose that information in a public trial or in the making of the court ' s decisions.

2. However, the provisions of paragraph (1) are not able to be construed in such a way that it imposes to any of the Parties on the Agreement of obligation to: a) perform administrative actions contrary to the laws or practices of the administration applicable in that Country or in the other party States on the Agreement; b) provide information that may not be obtained. By law or in the country of the country, or in the State of the United States, in the Agreement; c) provide information that reveals any secrets in the field of commerce, business, industry, commerce or business. expertise, or trade means or other information that is the applicability conflicting with the common wisdom (ordre public).

Article 27 DIPLOMATIC AND CONSULAR OFFICIALS

This agreement will not affect the preferable rights in the fiscal field of diplomatic and consular officials based on the common regulations of international law or based on The provisions of a special agreement.

Section 28 EXPIRES

1. This agreement will be in effect the following day after the date in which each Government informs each other in writing that the official formalities necessary in each of the countries have been met.

2. These provisions will apply: a) regarding the tax cut on the income source, for the income

obtained on or after the next January 1 year of inwim

after the enactment of this Agreement; b) regarding other taxes, the tax year begins on or after 1

January the next tadwim after the effective year of this Agreement.

Article 29 TERMINATION OF CONSENT

This agreement will remain in effect until terminated by one of the Parties to the Agreement. Each party country in the Agreement may terminate this Agreement, through diplomatic channels, by providing written notice of the termination of the Agreement at least 6 months prior to expiration of the Agreement. The next taxable after five (five) years since the expiration of the Agreement. In such case, this Agreement does not apply anymore: a) regarding taxes cut on the income source, for the amount of income,

for the amount of income paid or credited on or after 1 January the next tawim year after the year of notice of termination Approval is provided;

b) regarding other taxes on income, for tax years beginning on or after the next January 1 year of inwim after the year notice of the termination of the Agreement is granted.

As the evidence signed below, which has obtained a legitimate power has been signed this Agreement.

CREATED in double in Ulan Bator, on July 2, 1996, in Indonesian, Mongolian, and English, all three of the manuscripts are in the same name. In terms of differences in interpreting, then the prevailing is the English script.

FOR THE GOVERNMENT FOR THEwill apply to the first five years of this Agreement effective and authorized officials will consult with each other to formulate a specific tax-stimulation provision in connection with the application of this provision.

Section 24 NON DISCRIMINATION

1. The 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 different or more burdensome rather than the imposition of taxes and Obligations that are subject to or may be subjecresidence which is available to him; if he has a permanent residence available in the two countries, he will be considered a resident of the State where there is a Closer personal and economic relations (the center of principal interests); (b) if the country where the center of its interests cannot be determined, or if he does not have a place to remain available to him in the one of the countries, then he would only be regarded as a resident of the State where he according to usually (c) if he had a place of habit of sitting on either side of the State in the Agreement, or at all not having it in any of those countries, he would be considered a citizen of the State on the Agreement where he became a citizen. country; (d) If the status of the population cannot be determined in accordance with the paragraph a-c then the authorities of the State on the Agreement will resolve its issue by mutual consent.

3 If based on the provisions of the Agreement, the following terms apply. verse 1, an entity other than a person is a resident of both the State of the State approval, then the party authorities will solve the problem based on mutual consent.

Section 5

FORM A FIXED EFFORT

1. For the purposes of this Agreement, the term of the form of an effort remains a place of fixed effort in which all or part of the business of a company is run.

2. The term of the form of effort remains mainly: (a) a management position; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a warehouse or a storage place as a sales place; (g) a farm. or plantations; (h) a mine, an oil or gas well, a place of excavation or a place of exploitation of natural resources, a rig for drilling or vessels used for exploitation and exploration of natural resources.

3 Terms of business form still includes: (a) A building, a construction, assembly project or an installation project or surveillance activities that are related to the project and the exploration of natural resources, but only if buildings, projects or activities

and the exploration of such natural resources lasts for more than 6 months; (b) the granting of services, including consulting services performed by a company through its employees or other persons employed by that company. for such purposes, but only if such activities are ongoing (for the same subject or in relation) in a Country in a period or time of more than 1 month in a twelve month period.

4. Deviations from the previous provisions of this section of the term of the form of the business remain not considered to include: (a) the use of the facilities solely with the intent to store or display the goods or merchandise belonging to the other. company; (b) the business of an inventory of goods or merchandise belonging to the company solely with the intent to be stored or exhibited. (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 intention of purchase of goods or goods. merchandise or to disclose information for the benefit of the company; (e) the business of a business place remains solely with the intent for advertising purposes or to provide provisions for the purposes of the company; (f) the business of a business. the business place remains solely with the intent of running each activity other preparatory or support for the company; (g) the business of a business place remains solely with the intent to perform a combination of such activities mentioned on a sub-paragraph (a) up to the sub-paragraph (f), as long as the results of the company may be used. The merger of all such activities is preparation or support.

5. Deviations from the provisions of paragraph 1 and 2 if the person and body, except the free acting agent as applicable section 7 acts in a State of the State upon approval on behalf of a company based in the other State of the State in the United States. Approval, then the company is considered to have a form of a fixed effort in the first mentioned State for activities performed by the person or body for that if it is: (a) has and is authorized to confer and close the contracts on behalf of such companies unless such activities are limited to activities as set out in paragraph 4, which is done through a business place. fixed, it is not a form of effort to remain in accordance with the terms of the verse; or (b) it is not authorized to do so, but it is used to do inventory of goods or merchandise in the State called first. in which he regularly gives up goods or merchandise on behalf of The company; or (c) makes or processes in the country for the purposes of corporate goods or merchandise belonging to the company.

6. An insurance company from the State of the State on the Agreement, except those with respect to re-insurance will be deemed to have a fixed form of business in the other State on the Agreement if the company is picking up premiums in other areas of the country. and bear the risk going on there through

a clerk or through a representative who is not an agent acting freely as in verse (7).

7. A company from a party country in the Agreement will not be considered to have a fixed form of business in the other State of the Agreement solely because it runs a business in other States on the Agreement through the Agreement. makelar, a general commissioner agent, or any other agent who acts freely, as long as the person or body acts in the framework of his usual business activities. Nevertheless, when the agent's activities are meant entirely or almost entirely done for the company or its corporate allies, then he will not be considered a free-acting agent in the sense of this verse.

8. If a company based on a State of the Agreement is controlled or controlled by any other party in the State of the State in the Agreement or running an undertaking in other countries it is (well through a) The form of a fixed effort or one way or another), then it does not necessarily result in a fixed form of effort from another.

Article 6

THE INCOME OF THE NON-MOTION TREASURY

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

2. The term "non-motion" shall have a meaning in accordance with the laws of the State of the Parties to the Agreement where the property is concerned. The term includes the items that accompany the non-motion, livestock and equipment used in agricultural and forestry endeavour, the rights to which the provisions apply to the common law regarding possession of land, rights of the law. Collect the results of non-motion goods, as well as the rights to fixed or permanent payments for employment, or the right to work on the mineral content, sources and other sources of natural wealth; ships, boats, and other sources of the mineral resources. The airship is not considered a non-motion treasure.

3. The provisions of paragraph 1 apply also to the income obtained from the direct use, from the lease, or from the use of non-motion possessions in any form.

4. The provisions in verses 1 and 3 apply al State of the State may be taxed in the country by its domicility, place of the Agreement. The residence, the seat of the management, the location of the registration, or the other, is similar. But the term does not include persons and bodies of tax owed in the State only for obtaining income from the sources in the State.

2 If one according to the provisions of paragraph 1 became a resident in both Countries 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 place of wer.

2. The tax rate imposed by a party of the State on the Approval of interest from the source in the State of the State on Approval by the residents who enjoy the interest in the other State of the Agreement shall not exceed 10 percent. of the gross amount of interest.

3. Deviations from the provisions of the paragraph (2), the interest arising in the State on the Agreement and from the other party governments on the Agreement including, the government of the area of the country, the Central Bank, or any financial institution that is in the Agreement, the Agreement, the Agreement, the Agreement controlled by the government, whose capital is wholly owned by the Government of the other party on the Agreement, as it has been agreed upon from time to time between the officials the State of the Parties on the Agreement will be exempt from tax imposition in the State called first.

4. The term flower used in this section means the income of all types of debt bills, whether or not it is guaranteed by both mortgages and non-profits, which have the right to profit and profit sharing, and in particular income from State treasury letters and letters of bonds or letters of debt, including premiums and gifts tied to such valuable letters, bonds, or letters of debt, as well as all the income that is considered to be The income earned from the money loaned out.

5. The provisions of paragraph 1 to paragraph 2 shall not apply if the lender who enjoys the interest is based on a State of the Parties at the Agreement where the flower comes from a fixed form of effort that resides there, or running free work in other Countries through

A fixed entity located there, and a debt bill that produces the interest is an effective relationship with a) a fixed form of business or a fixed business place or with b) activities such as being referred to in the Article 7 of 1 letter c. In such case, depending on the problem, the provisions of Article 7 or Section 14.

6. Flowers are considered to be in a State of the Approval if the force is the State itself, the tightness part, the local government, or the population of the country. However, if a person or body is paying the interest, regardless of whether he is a member of a State on the Agreement or not, it has a fixed form or a place of effort in a State of the State on the Agreement where the interest rate is It will be deemed to be from the State of the Agreement where the form of a fixed effort or business place is located.

7. If there is a reason for a special relationship between a flower and a person who enjoys a flower or a person or another with regard to the size of a debt bill, if there is a special relationship between the two or two people, The payer and the recipient of the bunaga, or between them and the other, and the other, with regard to the bill of the debt, which is the basis of the payment, the amount of interest that exceeds the amount that is intended. payer and receiver if there is no such special relationship, then The provisions of this section apply only to the number of flowers called last. In such case, the amount of excess payment will remain taxed under the laws of each country with regard to the other provisions of this Agreement.

Article 12

ROYALTIES

1. Royalties from a party state in the Agreement and be paid to the residents of another State on the Agreement may be taxed in the other Country.

2. The tax rate imposed by one State on the Agreement on behalf of the royalties obtained from the source in the State of the State in the Agreement and its acceptance is the owner of the right who enjoys royalty it is a resident of the other State. on the Agreement, not to exceed 10 percent of the gross amount of royalty as referred to in paragraph (3).

3. The royalty term used in this section means the payments either periodically or not, and by any name or form or name that includes the rewards for: (a) use, or the right to use, any of the literature copyright, artistry or scientific work, patent, pattern or model, the formula or manner of an undisclosed processing, trademark or other property or other rights; or (b) use, or the right to use the tools of industrial equipment, commerce or science; or (c) the giving of science, engineering, industry or commerce, or (d) the giving of various assistance that is complementary and the addition of any such intangible property or the right of the so-called sub verse (a), any

equipment such as in sub paragraph (b) or any knowledge or information as mentioned in the sub paragraph (c), or. (e) use, or the right to use:

(i) cinema films; or (ii) films or videos used in conjunction with

television; or (iii) the tape used in conjunction with a radio broadcast; or

(f) hold all or part of the payment by due to the use or provision of the offering or the provision of the property or the rights designated in this paragraph.

4. The provisions of paragraph 1 and paragraph 2 do not apply, if the parties that have the right to enjoy, who are the residents of a party State on the Agreement, running the effort in the other State on the Agreement where the royalties are derived, through a the form of a fixed entity that resides there, or does a free work in the other country through a place of fixed effort, and the right or property that produces that royalty has an effective relationship with a) a fixed form of business rights or a fixed or with b) business activities such as referred to in Section 7 of paragraph 1 A c. In such case the provisions of Article 7 or Section 14 shall apply.

5. Royalties may be considered to be from the State of the Parties on the Agreement if payment is the State itself, the local government, or the population of the State. However, if a person or body is paying the royalties, regardless of whether he is a member of a State on the Agreement or not, has a fixed form or a place to remain in a State of the Union in the Agreement. The obligation to pay royalties arises, and the royalties be the burden of a fixed form or place of effort, then the royalties are considered to be from the State where the form of a fixed effort or place of effort is located.

6. If for the reason of the existence of a special relationship between the payer and the owner of the right who enjoys or between them and other persons, regarding the use of the rights or the information resulting in the payment, the amount of royalties that Paid for it exceeds the amount that the payer and the owner of the right will agree on if there is 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.

Article 13

THE ADVANTAGE OF A TREASURE TRANSFER

1 Advantage acquired by a citizen of a State on the Approval of a non-motion treasure transfer, as referred to in Section 6 and located in the other State of the Union Approval, may be taxed in other countries.

2 Advantage from the transfer of a treasure that is a part of the wealth of a fixed entity owned by the company of a party of the here, or running a free job with a fixed business place that is there and ownership of the stocks that generate that dividend has a relationship. which is effective in the form of a fixed effort or a fixed place of effort. In such case, depending on the problem, the provisions of Section 7 or Section 14.

Article 11

BUNGA

1. A flower that is derived from a party country on the Agreement and paid to the other party residents of the Agreement may be subject to tax on other States of the Agreement if the resident is a lender who enjoys the floting 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, which is accepted solely for the purpose of life, education or exercise of no taxes in the first mentioned State, as long as those payments are derived from the source in the outside of the country.

2. With respect to the grants, the students and the rewards of the work not covered in verse 1, a student or the intern mentioned in paragraph 1, in addition, entitled during an education or such training period is given The same exclusions or deductions that concern the taxes imposed on the residents of the State on the Agreement that he visited.

Article 22

OTHER INCOME

TYPES Income from the residents of the State on the Agreement, wherever the source is, not set in sections on Approval, in addition to earnings in the form of a lottery, the prize will be taxed in the Country.

Article 23

DOUBLE TAX AVOIDANCE

If a citizen of the State on the Agreement obtain the income from the other parties in the Agreement which, according to the provisions of this Agreement, the amount of taxes on such income paid in the State of the other on the consent may be credited with taxes in the State. The Approval Party was imposed on the population. Nevertheless, the sum of the credit should not exceed the tax portion in the State on the Approval of that income which is calculated in accordance with the legislation and its tax regulations.

Section 24

NON-DISCRIMINATION

1. The citizens of a State of the State in the Agreement shall not be subject to any tax or liability in respect of the tax imposition in the other State on the Discrete Consent or greater incrimination than the tax imposition and The obligations of the parties that are subject to or may be subject to the citizens of the other State are in the same state.

2. A tax charge on the form of a fixed entity owned by a corporation from the State of the State on 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 cannot be construed

to require a State of the Parties to the Agreement to provide to the residents of the other State on the Approval of a private cut, leniency and non-negation for the benefit of tax imposition based on civilian status or family responsibility as given to its own residents.

3. A Company in a State of the State on the Agreement, whose capital is partially or wholly owned or controlled directly or indirectly by the residents of the other party States on the Agreement, will not be taxed or any liability. with respect to tax imposition in the country, which is called first or more damning than the imposition of taxes and the obligations in question that are imposed or may be subject to other companies in the country of the country. The country 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 over such a company will be able to be deductable under the same conditions if it is paid to the inhabitants of the first called country.

5. The provisions of this Section are the terms of the taxes included in this Agreement.

Section 25

MARKING 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 The settlement is governed by the national laws of the respective States, then he may submit the issue to the officials in the State of the State in the Agreement where he is based, or any problem arising out of any of the matters. Paragraph 1, paragraph 1, paragraph 1, Section 5, Section 5, Section 5, Section 5, be a resident. 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 by the Agreement, in order to avoid the imposition of the tax that is not in compliance with this Agreement.

3. Officials who are authorized by both parties to the Agreement through a joint agreement must seek to resolve any difficulty or doubt arising in the interpretation or application of this Agreement. They can also consult together to prevent multiple tax imposition in terms of not in Approval.

4. Officials who are authorized by both parties to the Agreement may be directly related to each other in order to achieve approval as referred to in the preceding paragraphs. Authorized officials, through consultation, will develop procedures, conditions, ways

and technical are bilateral for the achievement of the consent procedures referred to in this Section.

Article 26

EXCHANGE OF INFORMATION

1. Authorized officials from both parties to the Agreement shall conduct the necessary information to carry out the provisions of this Agreement or to carry out the country's national laws. Each of the taxes included in the Agreement, as long as the tax charge according to the laws of the State is not contrary to this Agreement, in particular for the avoidance of embezzlement or tax evasion. The exchange of information is not limited by the provisions of Article 1. Any information that is received by a party in the Agreement must be kept in secrecy in the same manner as if the information is considered a secret it can only be disclosed to people or bodies or officials (including the courts and administrative bodies) that are interested in the designation or billing of taxes, the implementation of laws or prosecutions, or in deciding the objections to the taxes covered in the Agreement. Such persons or officers 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. How can the (1) provisions of the paragraph (1) be not able to be construed in such a way that it imposes to the State on the Agreement of obligation to: (a) carrying out administrative actions that are contrary to the The laws and regulations applicable to the State of the State or in the other countries of the State of the Agreement. (b) provide information that may not be obtained under the law or in the administration practice prevalent in the Country or in the Other State on the Agreement; (c) provide information that reveals any secrets in the fields of trade, business, industry, commerce or expertise, or trade ways, or any other information that is contrary to the wisdom of the State.

Article 27

DIPLOMATIC AND CONSULAR OFFICIALS

This agnsecutive years for teaching purposes, giving lectures. Or doing research in the institution is meant to be exempt from the imposition of taxes in the State of the Parties to the Agreement on the construction of such activities, provided that the payment by which it is derived from outside the State of the Parties to the Approval.

Article 21

STUDENTS AND INTERNS

1. Payments received by the student or the intern who is a resident or immediately before visi