The Double Taxation Relief (Taxes on Income) (Indonesia) Order 1994

ARTICLE 2 Taxes covered

(1) The taxes which are the subject of this Agreement are:

(a) in the United Kingdom:

(i) the income tax;

(ii) the corporation tax; and

(iii) the capital gains tax;

(hereinafter referred to as “United Kingdom tax”);

(b) in Indonesia:

the income tax (Pajak Penghasilan 1984), and to the extent provided in such income tax, the company tax (Pajak Perseroan 1925), and the tax on interest, dividends and royalties (Pajak Atas Bunga, Dividen dan Royalty 1970);

(hereinafter referred to as “Indonesian tax”).

(2) This Agreement shall also apply to any identical or substantially similar taxes which are imposed by either Contracting State after the date of signature of this Agreement in addition to, or in place of, the taxes referred to in paragraph (1) of this Article.The competent authorities of the Contracting States shall notify each other of any substantial changes which are made in their respective taxation laws.