Tax Court Ruling on Beneficial Ownership of Interest on Bonds Issued by Dutch Special Purpose Vehicle

Journal
Author
Karyadi, F.
Country
Indonesia
Published Date
Issue
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2010 (Volume 12), No. 6
FormatPDF
EUR
45
| USD
50 (VAT excl.)

A decision by Indonesia’s Tax Court has denied the application of the 0% withholding tax rate on interest as provided under the Indonesia–Netherlands income tax treaty. The determination of the beneficial owner of the income was central to the Court’s ruling.