Channel approach
Approach through " subject-to-tax" still have not guaranteed to inveterate strategy is called " stepping-stone strategy". Therefore approach by applying rule " subject-to-tax" must be equiped with " channel approach". Main principle in " channel approach" be that production obtained a company in domicile state from source state, is not used to fulfill obligation to third party livinging in third state. In recommending it OECD to give benchmark that production used for the exceeds 50% from production.
The approachs is upper that there are still need equiped with some rules so that the facility in Acceptance of Doubled Tax Avoidance really enjoyed by second tax subject of state. Based on recommendation from OECD addition of rule for approachs elaborated under, called as with " bona fide provisions", basically a company build in one of state is not solely with a view to enjoys rule in P3B.
In this relationship P3B Indonesia-Amerika has loaded the rules is upper, concerning two things that is i) to ensure that badan/perusahaan receiving production is company which its(the shareholder consisted of combination from tax subject from both states and ii) production obtained from state source of is not applied to close obligation to tax subject in third state. The order is loaded in Article 28(6) ( General Rules of Taxation), which its(the formula is as follows.
Approach through " subject-to-tax" still have not guaranteed to inveterate strategy is called " stepping-stone strategy". Therefore approach by applying rule " subject-to-tax" must be equiped with " channel approach". Main principle in " channel approach" be that production obtained a company in domicile state from source state, is not used to fulfill obligation to third party livinging in third state. In recommending it OECD to give benchmark that production used for the exceeds 50% from production.
The approachs is upper that there are still need equiped with some rules so that the facility in Acceptance of Doubled Tax Avoidance really enjoyed by second tax subject of state. Based on recommendation from OECD addition of rule for approachs elaborated under, called as with " bona fide provisions", basically a company build in one of state is not solely with a view to enjoys rule in P3B.
In this relationship P3B Indonesia-Amerika has loaded the rules is upper, concerning two things that is i) to ensure that badan/perusahaan receiving production is company which its(the shareholder consisted of combination from tax subject from both states and ii) production obtained from state source of is not applied to close obligation to tax subject in third state. The order is loaded in Article 28(6) ( General Rules of Taxation), which its(the formula is as follows.
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