Competent Authorities of Indonesia's Tax Treaty Partners

02-08-2018 - Kantor Pelayanan Pajak Madya Denpasar — Kantor Wilayah Direktorat Jenderal Pajak Bali
Based on the Directorate General of Taxes decree Number 10/PJ/2017 regarding provisions to claim the benefit of tax treaty existence, the Indonesian withholding agent should representing the DGT form to be fulfilled by foreign incomes recipient and then must be completed with legalization by the tax authority from the respecting country to be recognized by the Directorate General of Taxes. The form must be attached in every monthly tax return (mostly monthly tax return of Indonesia income tax law article 23/26). In fact, this particular formality is absolutely not an easy as it seems, otherwise seeing that the tariff will be under 20% up to 0% (based on each of the treaty) it is going to be worth to get. The only thing to do to take the advantage of the tariff is the Indonesia withholding agent and also foreign income recipient must be cooperated well to fulfill the form or all related documents.

Every country has their own government body or competent authority to legalize the document related to taxation and also to determine the residence of specific legal subject. According to the Directorate General of Taxes decree Number 10/PJ/2017, there are no explicit articles mentioning every competent authorities recognized by the Directorate General of Taxes. The only legal basis that Indonesia has is Directorate General of Taxes Letter number SE-20/PJ.34/1992 regarding list of competent authorities in each country which having double taxation avoidance agreement with Indonesia. That letter only providing information of 20 countries tax authorities. In contrast, by 2018 Indonesia had ratified the double taxation treaties with more than 60 countries. It means, some countries need to be explained clearly about the competent authority which recognized by the Directorate General of Taxes. It illustrates that Indonesia Directorate General of Taxes should updating the rule to make it much clearer.
In order to make less trouble in near future here are the list of tax authority of all countries that having double taxation agreement with Indonesia completed with the website, so every tax officer and tax payer will be able to research much more detail regarding the right form of Certificate of Residence to claim the advantages of tax treaty.

LIST OF COMPETENT AUTHORITIES OF INDONESIA'S TAX TREATY PARTNERS
 
1. South Africa Commissioner for Inland Revenue / South African Revenue Service
2. United States of America Secretary of the Treasury / Internal Revenue Service
3. Australia Commissioner of Taxation / Australian Taxation Office
4. The Kingdom of Netherlands Minister of Finance /  Belastingdienst (Tax and Customs Administration)
5. Hongkong Hong Kong Special Administrative Region the Commissioner of Inland Revenue / Inland Revenue Department
6. Republic of India Finance Minister /  Indian Revenue Service
7. United Kingdom Commissioners of Inland Revenue /  HM Revenue and Customs
8 Singapore The Minister of Finance /  Inland Revenue Authority of Singapore
9 The Kingdom of Spain the Minister of Economy and Finance /  Agencia Estatal de Administración Tributaria
10 Japan Minister of Finance / National Tax Agency
11 Republic of Korea Minister of Finance / National Tax Service
12 Canada Minister of National Revenue / Canada Revenue Agency / Agence du revenu du Canada
13 The Russian Federation Ministry of Finance / Federal Tax Service (Russia)
14 Malaysia Minister of Finance /  Lembaga Hasil Dalam Negeri Malaysia
15 Switzerland Director of the Federal Tax Administration /
16 Lao People’s Democratic Minister of Finance / Tax Department
17 Kingdom of Morocco Minister of Finance / The General Tax Administration
18 The Republic of Armenia The Minister of Finance and Economy and The Minister of State Revenue
19 Papua New Guinea The Commissioner General of Internal Revenue / Internal Revenue Commission
20 Islamic Republic of Iran The Minister of Economic Affairs and Finance / Iranian National Tax Administration
21 The Portuguese Republic The Minister of Finance, the Director General of Taxation (Director-Geral dos Impotos) /  Autoridade Tributária e Aduaneira
22 The People’s Republic of Bangladesh The National Board of Revenue
23 The United Mexican States The Ministry of Finance /  Servicio de Administración Tributaria
24 Algeria The Minister in charge of Finance / Direction Générale des Impôts
25 Austria The Federal Minister of Finance / Bundesministerium fur Finanzen
26 Belgium The Minister of Finance / The Federal Public Service Finance
27 France the Minister of the Budget / Directorate General of Public Finance
28 The Philippines The Minister of Finance /  Bureau of Internal Revenue
29 Poland Minister of Finance / Ministry of Finance (National Revenue Administration)
30 Qatar Minister of Finance / Public Revenues and Tax Department Ministry Of Finance
31 Czech Republic Minister of Finance / General Financial Directorate
32 Republic of Croatia The Minister of Finance / Tax Administration
33 Brunei Darusallam Minister of Finance / Ministry of Finance
34 Bulgaria Minister of Finance / National Revenue Agency
35 China State Administration of Taxation
36 Denmark The Danish Ministry of Taxation
37 Finland Ministry of Finance / Finnish Tax Administration
38 Hungary Minister of Finance/National Tax and Customs
39 Italy Ministry of Finance/Revenue Agency
40 Germany Federal Ministry of Finance/Federal Central Tax Office
41 Republic of Suriname Minister of Finance/Directorate of Taxes
42 Romania Minister of Finance/National Agency for Fiscal Administration
43 Saudi Arabia the Ministry of Finance and National Economy / General Authority of Zakat and Tax
44 New Zealand the Commissioner of Inland Revenue /Inland Revenue
45 Seychelles Minister of Finance/Seychelles Revenue Commission
46 Slovakia The Minister of Finance/Financial Administration
47 Sri Lanka Commissioner General of Inland Revenue / Sri Lankan Inland Revenue Department
48 Sudan Minister of Finance / Sudan Taxation Chamber
49 Syria Minister of Finance /  Ministry of Finance
50 Sweden Minister of Finance / Swedish Tax Agency
51 Democratic People’s Republic of Korea the Ministry of Finance / National Tax Service
52 Kuwait Minister of Finance /
53 Luxembourg Minister of Finance /  l'Administration des contributions directes
54 Egypt Minister of Finance / Egyptian Tax Authority
55 Mongolia Minister of Finance /  General Department of Taxation
56 Norway the Minister of Finance and Customs 
/  Norwegian Tax Administration
57 Pakistan Central Board of Revenue / Federal Board of Revenue
58 Taiwan Taipei Economic and Trade Office: the Director General, Department of Taxation, Ministry of Finance / National Taxation Bureau of Taipei
59 Thailand Minister of Finance/  The Customs, Excise and Revenue Departments
60 Tunisia Minister of Finance / Ministry of Finance
61 Turkey Minister of Finance / Turkish Revenue Administration
62 Ukraine Minister of Finance / State Fiscal Service of Ukraine
63 Uni Arab Emirates Minister of Finance and Industry / Ministry of Finance / Federal Tax Authority
64 Uzbekiztan the Chairman of the State Tax Committee
65 Venezuela SENIAT /  Integrated National Service of Customs and Tax Administration
66 Vietnam Minister of Finance / General Department of Taxation
67 Jordan Minister of Finance / Income and Sales Department of Tax
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