中国与印尼避免双重税收协定(英文).pdfVIP

AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND THE GOVERNMENT OF THE PEOPLES REPUBLIC OF CHINAFOR THE AVOIDANCE OF DOUBLE TAXATION ANDTHE PREVENTION OF FISCAL EVASIONWITH RESPECT TO TAXES ON INCOME The Government of the Republic of Indonesia and the Government of the Peoples Republic of China, DESIRING to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, HAVE AGREED AS FOLLOWS: Article 1 PERSONAL SCOPE This Agreement shall apply to persons who are residents of one or both of the Contracting States. Article 2 TAXES COVERED 1. This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its local authorities, irrespective of the manner in which they are levied. 2. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property. 3. The existing taxes to which the Agreement shall apply are: (a) in Indonesia: the income tax imposed under the income tax law of 1984 (Undang-undang Pajak Penghasilan l984, Law Number 7 of l983 as amended); (hereinafter referred to as Indonesian tax); (b) in the Peoples Republic of China: 1 i) the individual income tax; ii) the income tax for enterprises with foreign investment and foreign enterprises; iii) the local income tax; (hereinafter referred to as Chinese tax). 4. This Agreement shall also apply to any identical or substantially similar taxes which are imposed after the date of signature of the Agreement in addi