Tax Court Ruling on Beneficial Ownership of Interest on Bonds Issued by Dutch Special Purpose Vehicle

Journal
Karyadi, F.
Indonesia
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2010 (Volume 12), No. 6
PriceUSD 45

A decision by Indonesia’s Tax Court has denied the application of the 0% withholding tax rate on interest as provided under the Indonesia–Netherlands income tax treaty. The determination of the beneficial owner of the income was central to the Court’s ruling.