General rules of Taxation
Except as provided in paragraph 7, a person (other than an individual) which is a resident of a Contracting State shall not be entitled under this Convention to relief from taxation in the other Contracting State unless:
more than 50 percent of the beneficial interest in such person (or in the case of a company, more than 50 percent of the number of shares of each class of the company’s shares) is owned directly or indirectly by any combination of one or more:
• individuals who are residents of the United States;
• citizens of the United States;
• individuals who are residents of Indonesia;
• companies as described in paragraph (7)(a); and
• the Contracting States; and
the income of such person is not used in substantial part, directly or indirectly, to meet liabilities (including liabilities for interest or royalties) to persons other than those enumerated in subparagraphs (1) through (5).”
Sentence ( 6) letter ( a) for arranging about whosoever tax subject ( in this case is badan/perseroan) which [is] entitled to enjoy rule in P3B. Shareholder from copartnership is intended must be up to standard specified in sentence ( a). Letter ( b) from sentence ( 6) above is covenant that most of the production is not utilized to fulfill obligation to tax subject apart from mentioned in sub-ayat ( i) up ( vanadium).
Example of similar also can be met in P3B with English concerning payment of interest, arranged in Article 11(9), which its(the formula is as follows:
Except as provided in paragraph 7, a person (other than an individual) which is a resident of a Contracting State shall not be entitled under this Convention to relief from taxation in the other Contracting State unless:
more than 50 percent of the beneficial interest in such person (or in the case of a company, more than 50 percent of the number of shares of each class of the company’s shares) is owned directly or indirectly by any combination of one or more:
• individuals who are residents of the United States;
• citizens of the United States;
• individuals who are residents of Indonesia;
• companies as described in paragraph (7)(a); and
• the Contracting States; and
the income of such person is not used in substantial part, directly or indirectly, to meet liabilities (including liabilities for interest or royalties) to persons other than those enumerated in subparagraphs (1) through (5).”
Sentence ( 6) letter ( a) for arranging about whosoever tax subject ( in this case is badan/perseroan) which [is] entitled to enjoy rule in P3B. Shareholder from copartnership is intended must be up to standard specified in sentence ( a). Letter ( b) from sentence ( 6) above is covenant that most of the production is not utilized to fulfill obligation to tax subject apart from mentioned in sub-ayat ( i) up ( vanadium).
Example of similar also can be met in P3B with English concerning payment of interest, arranged in Article 11(9), which its(the formula is as follows:
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