Explanation of Proposed Protocol to the Income Tax Treaty Between the United States and Indonesia: To be Considered by the Committee on Foreign Relations, United States Senate
U.S. Government Printing Office, Jan 1, 1996 - Double taxation - 12 pages
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15 percent 30-percent withholding tax beneﬁcial owner branch proﬁts tax branch-level excess interest business proﬁts Convention provides Convention’s reduced rate derived from sources dividend equivalent amount dividends paid double taxation establishment or ﬁxed excess interest tax exemption from source ﬁxed base foreign corporation foreign tax credit gross amount imposes a 20-percent income tax treaty independent personal services individual or foreign Indonesia generally imposes interest paid Internal taxation rules maximum rate nonresident alien individual objectives of U.S. permanent establishment poration posed protocol proﬁts or income proposed protocol amends proposed protocol provides proposed protocol reduces Proposed protocol rules protocol amends Article rate of source rate of tax reduces the rate royalties rules The Convention source country tax speciﬁed subject to U.S. tax avoidance taxation rules United trade or business Treaties generally provide treaty country treaty partner U.S. business U.S. corporation U.S. model U.S. person U.S. tax treaties U.S. trade vention to reduce