Nama : Ramadhan

NPM : F 201010192
Jawaban Soal
Case Study
1. Perhitunan PPh !tas "una
Diketahui : Penghasilan Bunga : Rp. 250.000.000,00
Tarif Tax Treaty : 10%
Jaa! : PPh Pasal 2" atas Bunga : 10% # Rp. 250.000.000,00 $ R#. 2$.000.000%00
Article 11
INTEREST
1. Interest arising in a Contracting State and paid to a resident of the other Contracting State
may be taxed in that other State.
2. However, such interest may be taxed in the Contracting State in which it arises, and
according to the laws of that State, but if the recipient is the beneficial owner of the
interest, the tax so charged shall not exceed 1! of the gross amount of the interest.
Protocol
"rticle 2
#aragraph 2 of "rticle 11 of the "greement is amended by substituting for the words "15
per cent" the words "10 per cent".
2. Perhitunan PPh !tas Royalti
Diketahui : Penghasilan Bunga : Rp. %50.000.000,00
Tarif Tax Treaty : 10%
Jaa! : PPh Pasal 2" atas R&yalti : 10% # Rp. %50.000.000,00 $ R#. &$.000.000%00
Article 12
ROYALTIES
1. $oyalties arising in a Contracting State and paid to a resident of the other Contracting State
may be taxed in that other State.
2. However, such royalties may also be taxed in the Contracting State in which they arise, and
according to the laws of that State, but if the recipient is the beneficial owner of the royalties,
the tax so charged shall not exceed 1! of the gross amount of the royalties.
Protocol
"rticle %
#aragraph 2 of "rticle 12 of the "greement is amended by substituting for the words &1 per
cent& the words &1' per cent&.
'. Perhitunan PPh atas (mbalan sehubunan denan #e)er*aan
'. Diketahui : Penghasilan Brut& (r. )illia* : + %250 # Rp. ,.0%%,00 $ Rp.
-..%-/.000,00
Tarif Tax Treaty : 20%
Jaa!an : PPh Pasal 2" (r. )illia*: 20% # Rp. -..%-/.000,00 $ Rp.
/."./.%00,00
Article 16
E!ENENT !ERSONAL SER"I#ES
1. (ages, salaries, and similar remuneration derived by an individual who is a resident of one of the
Contracting States from labor or personal services performed as an employee, including income
from services performed by an officer of a corporation or company, may be taxed by that
Contracting State. )xcept as provided by paragraph 2, such remuneration derived from sources
within the other Contracting State may also be taxed by that other Contracting State
2. $emuneration described in paragraph 1 derived by an individual who is a resident of one of the
Contractng States shall be exempt from tax by the other Contracting State if *
(a)
He is present in that other Contracting State for a period or periods aggregating less than
12' days in any consecutive 12+month period , and
(b)
the remuneration is paid by, or on behalf of, an employer who is not a resident of that
other State, and
(c) the remuneration is not borne as such or reimbursed by a permanent establishment
which the employer has in that other Contracting State.
B. Diketahui : Penghasilan Brut& (r. (a0hael : + %000 # Rp. ..,.,,," $ Rp.
-5.,5,..%0,00
Tarif Tax Treaty : 20%
Jaa!an : PPh Pasal 2" (r. (a0hael: 20% # Rp. Rp. -5.,5,..%0,00 $ Rp.
/.1,1.,".,00
Article 15
E!ENENT !ERSONAL SER"I#ES
1. Sub-ect to the provisions of "rticles 1., 1/, 10 and 2', salaries, wages and other similar
remuneration derived by an individual who is a resident of one of the Contracting States in respect
of an employment shall be taxable only in that State unless the employment is exercised in the
other Contracting State. If the employment is so exercised, such remuneration as is derived from
that exercise may be taxed in that other State.
2. 1otwithstanding the provisions of paragraph 1, remuneration derived by an individual who is a
resident of one of the Contracting States in respect of an employment exercised in the other
Contracting State shall be taxable only in the first+mentioned State if*
(a)
the recipient is present in that other State for a period or periods not exceeding in the aggregate 12'
days in any period of 12 months, and
(b)
the remuneration is paid by, or on behalf of, an employer who is not a resident of that other State,
and
(c) the remuneration is not deductible in determining taxable profits of a permanent establishment or a
fixed base which the employer has in that other State, and
(d) the remuneration is, or upon the application of this "rticle will be, sub-ect to tax in the first+mentioned
State.
%. 1otwithstanding the preceding provisions of this "rticle, remuneration in respect of an employment
exercised aboard a ship or aircraft operated in international traffic by a resident of one of the
Contracting States may be taxed in that State.