Second transaction is that John Doe works in two companies out of one groups, which in the transaction SUDSIDICO-2 doesn't receive fee in the relation with discharging John Doe for the sake of SUBSIDICO-1. What treatment of its(the PPh to the transaction? Earns DITJEN PAJAK to apply " imputed income" to the transaction? If the answer " positive" arises problem how much/many production from the transaction? SUBSIDICO-2 might possibly be snared in problem " form of permanent business ( BUT)" because John Doe its(the status is employee from SUBSIDICO-2 is residing in Singapore. This situation can be assumed represents SUBSIDICO-2 so that this company will be assumed had BUT in Singapore if fulfilling time test as arranged in Section 5(2)i from P3B Indonesia-Singapura. Problem faced by Singapore in this case equal to Indonesia in the case of determining how much/many production from " BUT SUBSIDICO-2" from activity gives the service.
From situation that is told upper seen that SOP launched by PARENTCo to John Doe, what obtains the benefit not only John Doe but also SUBSIDICO-1 livinging in Singapore.
Difficulty told upper caused by the transaction only seen rashers so that its(the trouble-shooting nor zero in. This thing is not to mention if evaluated from treatment of income tax to fee received by John Doe in the transaction.
This solvable problem passed approach optimally chain P3B. Case presented upper entangling three different tax jurisdictions. If third of the state admission in chain P3B hence its(the handling would easier. Exploiting of P3B maximumly need to be gone through through exchanges of off the cuff in character information. The concerned " exchanges of information spontaneously" be information sent by a state concerning other state taxpayer as result of tax audit done by state so-called first.
Transaction taken as case study is upper will only can be detected if one of state to do inspection of tax so that its(the transaction will be able to be known. Till now exchanges of information only be convergent to exchanges of in character information automatic ( automatic exchange of information), which only include;cover liability income. this type Information Interchange also will assist imposition of tax to the employee from the aspect of approach remunerasi received by it.
From situation that is told upper seen that SOP launched by PARENTCo to John Doe, what obtains the benefit not only John Doe but also SUBSIDICO-1 livinging in Singapore.
Difficulty told upper caused by the transaction only seen rashers so that its(the trouble-shooting nor zero in. This thing is not to mention if evaluated from treatment of income tax to fee received by John Doe in the transaction.
This solvable problem passed approach optimally chain P3B. Case presented upper entangling three different tax jurisdictions. If third of the state admission in chain P3B hence its(the handling would easier. Exploiting of P3B maximumly need to be gone through through exchanges of off the cuff in character information. The concerned " exchanges of information spontaneously" be information sent by a state concerning other state taxpayer as result of tax audit done by state so-called first.
Transaction taken as case study is upper will only can be detected if one of state to do inspection of tax so that its(the transaction will be able to be known. Till now exchanges of information only be convergent to exchanges of in character information automatic ( automatic exchange of information), which only include;cover liability income. this type Information Interchange also will assist imposition of tax to the employee from the aspect of approach remunerasi received by it.
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