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Indonesia Amends Regulation on Deemed Dividends from CFCs

25 July 2019

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Approved Changes

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Indonesia

Indonesia's Ministry of Finance has issued Regulation 93/PMK.03/2019, which amends Regulation 107/PMK.03/2017 on deemed dividends from unlisted controlled foreign companies (CFCs). This includes amendments to the types of CFC income that may be treated as deemed dividends, as well as amendments to the calculation of the deemed dividend amount. With respect to the type of CFC income, Regulation 93/PMK.03/2019 provides that instead of including all post-tax CFC income, deemed dividends will only include certain passive CFC income, including: Dividends, except for dividends received/obtained from other CFCs; Interest, except for interest received/obtained by a CFC owned by a domestic Indonesian taxpayer...