SolvedDT9652 | Double Taxation Relief Manual: Indonesia: treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Indonesia is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 15% | 10 |
| Dividends on direct investments | 10% | 10 |
| Conditions for lower rate on dividends on direct investments | A company which controls directly or indirectly at least 10% of the voting power in the company paying the dividends | 10 |
| Property income dividends | See rates above | 10 |
| Interest | 10% (Note 1) | 11 |
| Royalties | 10%/15% (Note 2) | 12 |
| Government pensions | Taxable only in Indonesia unless the individual is a resident and national of the UK | 19 |
| Other pensions | Taxable in both the UK and Indonesia | 18 |
| Arbitration | No | N/A |
Note 1: Interest is exempt from tax in Indonesia where it is:
paid to the UK government or political subdivision, or a UK local authority
paid in respect of a loan made, guaranteed or insured by the UK Export Credits Guarantee Department or the Commonwealth Development Corporation, or is beneficially owned by the UK Government
Note 2: The reduced rate of 10% applies to payments for the use of, or the right to use, any industrial, commercial or scientific equipment (equipment leasing payments).