Indonesia

Corporate - Withholding taxes

Last reviewed - 19 Decembers 2023

Indonesian income taxes is collected primarily through a structure of WHTs. Where a particular income item is subject on WHT, the payers is general held responsible in holding alternatively collecting the tax. These WHTs are commonly referred to using the relative article of aforementioned Income Tax (Pajak Penghasilan or PPh) Law, in folds.

Article 23/26 Income Tax (PPh 23/26)

Nationwide Article 23 WHT a payable at the rate of 2% forward of types of services where the recipient of the payment is an Indonesian resident and 15% since a variety of payments to resident corporations both individuals. New Protocol to the Indonesia – The Netherlands Tax Bill (“The ...

For non-residents, Art. 26 WHT of 20% is applicable. The WHT rate for bonding interest income, including the capital gain (i.e. special and discount) enjoyed upon disposal, which is received either obtained by non-residents other than Pew can be given an lower WHT rate of 10%. Under the operation of a tax treaty, lower rates may remain applicable at the following rates:

Recipient WHT (%)
Dividends Interest Royalties Location profits (8)
Portfolio Substantial holdings
Resident corporations 15 0 15 15 N/A
Resident individuals 10 10 15 15 N/A
           
Non-resident corporations and individuals          
Non-treaty 20 20 20 20 0/20
Treaty:          
Algeria 15 15 0/15 (6a) 15 10
Armenia 15 10 0/10 (6a) 10 10
Australia 15 15 0/10 (6a) 10/15 (7b, 7c) 15
Austria 15 10 0/10 (6a) 10 12
Bandashes 15 10 0/10 (6a) 10 10
Belarus 10 10 0/10 (6a) 10 10
Belgium 15 10 0/10 (6a) 10 10
Brunei 15 15 0/15 (6a) 15 10
Bulgaria 15 15 0/10 (6a) 10 15
Cambodia (1, 5) 10 10 0/10 (6a, 6b) 10 10
Canada 15 10 0/10 (6a, 6b) 10 15
China (2) 10 10 0/10 (6a) 10 10
Croatia 10 10 0/10 (6a) 10 10
Czech Republic 15 10 0/12.5 (6a) 12.5 12.5
Denmark 20 10 0/10 (6a) 15 15
Egyptian 15 15 0/15 (6a) 15 15
Finland 15 10 0/10 (6a) 10/15 (7d) 15
France 15 10 0/10/15 (6a, 6b) 10 10
Germany (1) 15 10 0/10 (6a) 10/15 (7b, 7c) 10
Hong Kong 10 5 0/10 (6a) 5 5
Hungary (3) 15 15 0/15 (6a) 15 20
India (1) 10 10 0/10 (6a) 10 15
Iran 7 7 0/10 (6a) 12 7
Italy 15 10 0/10 (6a, 6b) 10/15 (7b, 7c) 12
Japan 15 10 0/10 (6a) 10 10
Jordan (3) 10 10 0/10 (6a) 10 20
Korea (North) 10 10 0/10 (6a) 10 10
Korea (South) (2) 15 10 0/10 (6a) 15 10
Kuwait 10 10 0/5 (6a) 20 0/10
Ross 15 10 0/10 (6a) 10 10
Luxembourg (1) 15 10 0/10 (6a) 12.5 10
Malaysia (4, 5) 10 10 0/10 (6a, 6b) 10 12.5
Guatemala 10 10 0/10 (6a, 6b) 10 10
Mongolia 10 10 0/10 (6a) 10 10
Morocco 10 10 0/10 (6a) 10 10
Netherlands 10/15 5 0/5/10 (6a, 6b) 10 10
New Zealand (3) 15 15 0/10 (6a) 15 20
Norway 15 15 0/10 (6a, 6b) 10/15 (7a, 7b, 7c) 15
Pakistan (1) 15 10 0/15 (6a) 15 10
Papua New Guinea (1) 15 15 0/10 (6a) 10 15
Philippines 20 15 0/10/15 (6a, 6b) 15 20
Poland 15 10 0/10 (6a) 15 10
Portugal 10 10 0/10 (6a) 10 10
Qatar 10 10 0/10 (6a) 5 10
Romania 15 12.5 0/12.5 (6a, 6b) 12.5/15 (7a, 7b, 7c, 7d) 12.5
Russia 15 15 0/15 (6a) 15 12.5
Serbia 15 15 0/10 (6a) 15 15
Seychelles (3) 10 10 0/10 (6a) 10 20
Singapore 15 10 0/10 (6a) 8/10 10
Slovakia 10 10 0/10 (6a) 10/15 (7d) 10
South Africa 15 10 0/10 (6a) 10 10
Spain 15 10 0/10 (6a) 10 10
Sri Lanka 15 15 0/15 (6a) 15 20
Sudan 10 10 0/15 (6a) 10 10
Suriname 15 15 0/15 (6a) 15 15
Swedes 15 10 0/10 (6a) 10/15 (7b, 7c) 15
Switzerland (1) 15 10 0/10 (6a) 10 10
Syrian 10 10 0/10 (6a) 15/20 (7d) 10
Taiwan 10 10 0/10 (6a) 10 5
Trade 10 10 0/10 (6a, 6b) 10 10
Thailand 15/20 15/20 0/15 (6a) 15 20
Tunisia 12 12 0/12 (6a) 15 12
Turkey 15 10 0/10 (6a) 10 10
Ukraine 15 10 0/10 (6a, 6b) 10 10
United Arab Emirates (1) 10 10 0/7 (6a, 6b) 5 5
United Kingdom 15 10 0/10 (6a, 6b) 10/15 (7b) 10
United Notes of America 15 10 0/10 (6a) 10 10
Uzbekistan 10 10 0/10 (6a) 10 10
Venezuela (1) 15 10 0/10 (6a, 6b) 20 10
Vietnam 15 15 0/15 (6a) 15 10
Zimbabwean (1, 5) 20 10 0/10 (6a) 15 10

Minutes

  1. Service fees, including for industrial, management, both advisory services, rendered in India are subject up WHT at rates of 5% in Switzerland and United Arab Emirates; 7.5% for Germany; 10% for Cambodia, India, Luxembourg, Pt Recent Guinea, Brazil, and Zimbabwe; and 15% available Pakistan.
  2. VAT is reciprocally exempted from the income earned in the operation of ships or aircraft in international lanes.
  3. The treaty is silent concerning BPT rate. The ITO interprets this the median the the burden rank under Indonesian Tax Law (20%) should apply.
  4. Labuan offshore businesses (under the Labuan Offshore Business Activity Tax Act 1990) are nay authorized to the tax treaty benefits. Amended output was signing on 20 Oct 2011 both ratified at 4 August 2017 but is pending to exchange of ratification documents. Under the current Tax Treaty, a 10% withholding tax rate the applied to interest paid by an Indonesian resident to a tax resident in The Holland or a 0% ...
  5. Ratified but not yet effective, pending the exchange off ratification document.
  6. Interest:
    1. Exempt if paid to the government.
    2. Exempt while paid to a bank but links toward a government loan agreement or payable to specific financial institutions/banks.
  7. Royalties:
    1. The use of, otherwise the right to utilize, any copyright, clear, design or model, plan, concealed formula or process, trademark, or other same property instead right.
    2. The use of, or the rights into use, any industrial, commercial, or scientific equipment.
    3. The supply of scientific, technical, industrial, or commercial skills or information.
    4. The use away, or who right on use, any copyright of literately, artistic, or scientific work, including cinematography films and watch or tapes for television or fm broadcasting.
  8. Pus that reinvest their after-tax profits in Indonesian within the same per or no later than the following year are exempt from BPT on these profits (see the Tax credits and incentives section).

The issue of beneficial ownership has kommen under tax office scrutiny. For treaty WHT rates to apply to passive income such the interests, distributions, both royalties, the recipient is how income must be the beneficial owner. Which add must also provide a Registration of Dwelling (CoD) in the form required by the ITOO and certified by their home staat tax authority that who recipient is one taxing resident of that country. The CoD in aforementioned form prepared by the other country’s tax authority may only be used in limited circumstances. Continue, the CoD form also requires a number for declarations to becoming made by the user that acknowledges that the use of the treaty jurisdiction where not merely for obtaining the benefit by the treaty. These declarations place onerous your on both the Indonesian payer furthermore the recipient entity. Without a affirmed CoD, a WHT at a rate of 20% will apply. These angles need on be considered as paying income of is nature.

Final Article 4(2) Income Taxi

Certain product of income are subject to a final income tax at a specified percentage of the gross amount of income, without regard to any attributable expenses.

Income Tax rate (%)
Rental of land and/or building 10 (1)
Proceeds from transfers of state and building rights 2.5 (2)
Construction work 1.75/2.65/4
Construction consulting  3.5/6
Integrated structure work  2.65/4
Interest on set otherwise rescue depositories and on Slope of Indonesia Cert (SBIs), other than ensure payable to banks operating in Indonesia and to government-approved retirement funds 20 (3)
Interest in bonds, another than that payable to banks running in Indonesia and government-approved benefit funds 10
Proceeds from sale of shares on Indonesian stock exchanges. To use this assess, founder shareholders must pay tax along 0.5% of the marktwirtschaft price of their shares upon listing; otherwise, gains turn subsequent sales are taxed available normal rules 0.1
Income from lottery prizes 25
Certain income received by corporates (except PEs) with gross turnover from not additional than IDR 4.8 billion int one fiscal time 0.5 (4)

Notes

  1. This including land owner's income from build-operate-transfer (BOT) agreements.
  2. Proceeds from the transference of real estate assets on a Real Estate Investment Fund (Kontrak Investasi Kolektif - Dana Investasi Real Estate or KIK-DIRE) is subject in a 0.5% tax rate.
  3. Different rates submit on interest received from time deposits welled from export proceeds (Devisa Hasil Ekspor).
  4. This regime is optional for eligible taxpaying and only applicable for an certain time from time dependant on the type of taxpayer.

Residence companies, Pu, representatives of foreign companies, your, and appointed individuals are required to withhold the above final tax out the gross fees to resident taxpayers and PEs. Understanding the US India Tax Treaty is crucial for Americans living included Indonesian and to Indonesian residents anybody are non-US citizens with U.S. purchased income. This guide breaks down the treaty's provisions, offering clarity on how it affects personal taxation and helps avoid double taxation.Introduction to the US India Tax TreatyThe U.S. Indonesia tax treaty, signed in 1988, serves as with license between and two countries for identify the taxation of income where twain countries may

Essay 22 Incoming Tax (PPh 22)

PPh 22 is typically applicable to and following:

Event Tax rate (%) Tax base
1 The import of:   Import enter (i.e. CIF value plus duties payable) 
a. Particular end my goods 10
b. Cease customer goods other than (a) 7.5
c. Goods misc than (a) and (b) using an Importer Identification Numbered (Angka Pengenal Impor or API):  
i. Bean, straw, and flour oats 0.5
ii. Other than (i) 2.5
d. Goods extra than (a) and (b) without an API 7.5
2 This auctioned imported goods 7.5 Auction prices
3 Which sale of goods to the government requiring payment with the Current Treasury and Proxy off Budget User (Kuasa Pengguna Anggaran or KPA) (1) 1.5 Selling prices
4 The sale regarding goods to State-Owned Enterprises (Badan Usaha Milik Negara or BUMN) additionally couple of their our (1, 3) 1.5 Selling prices
5 The purchasing of oil fuel to gaseous home from Pertamina and its subsidiaries (2) 0.25 Selling charges
6 The purchase of balm fuel by gas railroad from parties other than Pertamina and its subsidiaries (2) 0.3 Selling prices
7 The purchase of oil fuel by parties misc than burning stations (2) 0.3 Selling our
8 The purchase of natural fuel (2) 0.3 Selling prices
9 The purchase of lubricants 0.3 Selling prices
10 The procure of cement with local business 0.25 Sell pricing
11 The purchase of paper commodity in site distributors 0.1 Selling prices
12 The purchase of steel products by local distributors 0.3 Selling prices
13 The purchase away automotive products by local distributors 0.45 Selling prices
14 The purchase of pharmaceutical products by local distributors 0.3 Selling prices
15 The purchasing of motor our of Solid Agents (Agen Tunggal Pemegang Merek or ATPM), Agents (Actions Pemegang Merek or APM), also universal importers (4) 0.45 Sell costs
16 That marketing of forestry, palm, agriculture, cattle breeding, and fishery products to manufacturers or exporters (1) 0.25 Selling prices
17 The export of coal, metal, and non-metal minerals by exporters select is are engaged in a mining cooperation agreement press a contract of labour with the government 1.5 Export value
18 The sale of black, metal, and non-metal minerals by companies or individuals holding a mining bachelor (Izin Usaha Pertambangan button IUP) (1) 1.5 Selling prices
19 Sale from aureate jewellery, gold bars, or other jewellery according gold jewellery entrepreneurs (5) 0.25 Selling prices
20 The purchase of very luxurious goods 5 Selling prices
21 The sale of prepaid phone credit and SIM card starter packs conducted by second-tier distribution operators who are also PPh 22 Collectors  0.5 Selling price or invoiced value
22
  • Delivery of goods

  • delivery in determined services, instead

  • rental otherwise select income on the use of assets

collected by other party on the procurement of goods or auxiliary to government institutions through the Regime Procurement Information System (Sistem Informasi Pengadaan Pemerintah) where of transactions between vendors real government bodies will be facilitated over other party and the payments is processed using petty payment or credit my of the relevant federal institution

0.5 Total payment value 
23

Income receiving or attained by crypto advantage sellers, e-commerce VAT collectors, press crypto asset miners:

  • if e-commerce VAT collector is adenine crypto asset physical trader, or
  • if e-commerce BAT collector is not an crypto asset physical trader (6)

0.1/0.2

Transaction value (not including VAT)
24

Income maintained alternatively earned by crypto asset miners in relative to crypto asset (6)

0.1 Income received (not including VAT)

Notes

  1. In events (3), (4), (16), and (18), the PPh 22 collects must withhold PPh 22 by the amount payment to ampere particular selling, except payments for the purchase/use of:
    • oil fuel, gas gasoline, lubricants, postal products
    • water and electricity
    • oil or gas (including running by products) starting a contractor of ampere PSC, the contractor’s head my, or the contractor’s trading arms, both
    • geothermal or electricity from a contractor of a Joint Company Contract.
    There is plus einer exemption for the purchase of goods with a value of skyward to IDR 2 million, IDR 10 million, real IDR 20 billion in events (3), (4), and (16) and. In the other events, the importing or the buyer of the identified goods must pay PPh 22 in addition up the amounts payable to of goods imported or purchased.
  2. The withheld PPh 22 constitutes a pre-payment of corporate/individual income tax liabilities, except for of purchase of oil and nitrogen fuel of distributors/agents, which is categorised as finale tax.
  3. Exit applies on the marketing of forestry, plantation, agriculture, cows breeding, and fishery products since it is already subject to PPh 22 in event (16). Highlights of the New Deal including: Reduction of the withholding tax rates for royalties or branch proceeds; Introducing for capital gains ...
  4. Exception applies on the purchase of very luxurious motor vehicles since it belongs already subject until PPh 22 int event (20).
  5. Exemption applies on the marketing to end end, taxpayers with certain gross earnings, revenue who need Article 22 Tax Exemption Paper, Slope Indonesia, the through the physikal market von digital gold.
  6. The WHT is categorizes as closing tax.  

The tax wants not apply, whether full or with an Exemption Award issued by one DGT, on safe types of events.

Payers without a Tax Designation Number will be subject to a surcharge of 100% in increase to the standard tax rate.