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Jordan

Indonesia has established tax treaties with Jordan to prevent double taxation and encourage cross-border investments. See detailed information on Indonesia-Jordan tax treaties below.

AGREEMENT
BETWEEN
THE GOVERNMENT OF THE REPUBLIC OF INDONESIA
AND
THE GOVERNMENT OF THE HASHEMITE KINGDOM OF JORDAN

FOR
THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION
WITH RESPECT TO TAXES ON INCOME

Article
1
PERSONAL SCOPE

This Agreement shall apply to
persons
who are residents of one or both of the Contacting States.

Article
2
TAXES COVERED

  1. This Agreement shall apply to
    taxes on income imposed on behalf of each Contracting State or of its
    political subdivisions or 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
    lndonesia:
    the income tax imposed under the Undang-undang Pajak Penghasilan 1984
    (Law No. 7 of 1983 as amended.)
    (hereinafter referred to as Indonesian tax).
    (b)

    In Jordan:
    – the income tax;
    – the distribution tax;
    – the social service tax;
    (hereinafter referred to as Jordanian tax).

  4. The Agreement shall apply
    also to any identical or substantially similar taxes which are imposed
    after the date of signature of the Agreement in addition to, or in
    place of, the existing taxes. The competent authorities of the
    Contracting States shall notify each other of any substantial changes,
    which have been made in their respective taxation laws.

Article
3
GENERAL DEFINITIONS

  1. For the purposes of this
    Agreement, unless the context otherwise requires;

    (a) (i)

    the term “Indonesia”
    comprises the territory of the Republic of Indonesia as defined in its
    laws;
    (ii)

    the term “Jordan” means the
    territories of the Hashemite Kingdom of Jordan, the territorial waters
    of Jordan and the seabed and subsoil of the territorial waters, and
    includes any are extending beyond the limits of the territorial waters
    of Jordan, the seabed and subsoil of any such area, which has been or
    may hereafter be designated, under the laws of Jordan, in accordance
    with international law, as an are over which Jordan
    has sovereign rights for the purposes of exploring and
    exploiting the natural resources, whether living or non-living;
    (b)

    the term “person” includes an
    individual, a company and any other body of persons;
    (c)

    the term “company” means any
    body corporate or any entity which is treated as a body corporate for
    tax purposes;
    (d)

    the terms “enterprise of a
    Contracting State” and “enterprise of the other Contracting State” mean
    respectively an enterprise carried on by a resident of a Contracting
    State and an enterprise carried on by a resident of the other
    Contracting State;
    (e)

    term “International traffic”
    means any transport by a ship or aircraft operated by an enterprise of
    a Contracting State, except when the ship or aircraft is operated
    solely between places in the other Contracting State;
    (f)

    the term “competent
    authority” means:
    (i)

    in Indonesia:
    the Minister of Finance or his authorised representative;
    (ii)

    in the case of Jordan:
    the Minister of Finance or his authorised representative;
    (g)

    the term “national” means:
    (i)

    any individual possessing the
    nationality of a Contracting State;
    (ii)

    any legal person, partnership
    and association deriving its status as such from the laws in force in a
    Contracting State;
    (h)

    the term “fixed base” means a
    permanent place in which professional activities are exercised.

  2. As regards the application of
    the
    Agreement by a Contracting State any term not defined therein shall,
    unless the context otherwise requires, have the meaning which it has
    under the laws of that State concerning the taxes to which the
    Agreement applies.

Article
4
RESIDENT

  1. For the purposes of this
    Agreement, the term “resident of a Contracting State” means any persons
    who, under the laws of that State, is liable to tax therein by reason
    of this domicile, residence, place of management or any other criterion
    of similar nature. But this term does not include any person who is
    liable to tax in that State in respect only of income from sources in
    that State.

  2. Where by reason of the
    provisions
    of paragraph 1 an individual is a resident of both Contracting States,
    then his status shall be determined as follows:

    (a)

    he shall be deemed to be a
    resident of the State in which he has a permanent home available to
    him; if he has a permanent home available to him in both States, he
    shall be deemed to be a resident of the State with which his personal
    and economic relations are closer (center of vital interests);
    (b)

    if the State in which he has
    his centre of vital interests cannot be determined, or if he has not a
    permanent home available to him in either State, he shall be deemed to
    be a resident of the State in which he has an habitual abode;
    (c)

    if he has an habitual abode
    in both States or in neither of them, he shall be deemed to be a
    resident of the State of which he is a national;
    (d)

    if the status of resident
    cannot be determined according to sub-paragraphs a-c, the competent
    authorities of the Contracting States shall settle the question by
    mutual agreement.

  3. Where by reason of the
    provisions
    of paragraph 1 a person other than an individual is a resident of both
    Contracting States, the competent authorities of the States shall
    settle the question by mutual agreement.

Article
5
PERMANENT ESTABLISHMENT

  1. For the purposes of this
    Agreement, the term “permanent establishment” means a fixed place of
    business through which the business of an enterprise is wholly or
    partly carried on.

  2. The term permanent
    establishment
    shall include especially:

    (a) a
    place of
    management;
    (b) a
    branch;
    (c) an
    office;
    (d) a
    factory;
    (e) a
    workshop;
    (f) a
    warehouse
    or premises used as sales outlet;
    (g) a
    farm or
    plantation;
    (h)

    a mine, an oil of gas well,
    a quarry or other place of extraction of natural resources, drilling
    rig or working ship used for exploration or exploitation of natural
    resources.

  3. The term permanent
    establishment
    likewise encompasses:

    (a)

    a building site, a
    construction assembly or installation project or supervisory activities
    in connection therewith, but only where such site, project or
    activities continue for a period of more than six months;
    (b)

    the furnishing of services,
    including consultancy services, by an enterprise
    through employees or other personnel engaged by the enterprise
    for such purposes, but only where activities of that nature continue
    (for the same or a connected project) within the country for a period
    or periods aggregating more than one month within any twelve-month
    period.

  4. Notwithstanding the preceding
    provision of this Article, the term permanent establishment shall be
    deemed not to include:

    (a)

    the use of facilities solely
    for the purpose of storage or display of goods or merchandise belonging
    to the enterprise;
    (b)

    the maintenance of a stock
    of goods or merchandise belonging to the enterprise solely for the
    purpose of storage or display;
    (c)

    the maintenance of a stock
    of goods or merchandise belonging to the enterprise solely for the
    purpose of processing by another enterprise;
    (d)

    the maintenance of a fixed
    place of business solely for the purpose of purchasing goods or
    merchandise, or for collecting information, for the enterprise;
    (e)

    the maintenance of a fixed
    place of business solely for the purpose of advertising, or for the
    supply of information;
    (f)

    the maintenance of a fixed
    place of business solely for the purpose of carrying on, for the
    enterprise, any other activity of a preparatory or auxiliary character,
    (g)

    the maintenance of a fixed
    place of business solely for any combination of activities mentioned in
    sub-paragraphs (a) to (f), provided that the overall activity of the
    fixed place of business resulting from this combination is of a
    preparatory or auxiliary character.

  5. Notwithstanding the provisions
    of
    paragraphs 1 and 2, where a person – other than an agent of an
    independent status to whom paragraph 7 applies – is acting in a
    Contracting State on behalf of an enterprise of the other Contracting
    State, that enterprise shall be deemed to have a permanent
    establishment in the first-mentioned State in respect of any activities
    which that person undertakes for the enterprise, if such a person:

    (a)

    has and habitually exercises
    in that State an authority to conclude contracts in the name of the
    enterprise, unless the activities of such person are limited
    to those mentioned in paragraph 4 which, if exercise through a
    fixed place of business, would not make this fixed place of business a
    permanent establishment under the provisions of that paragraph; or
    (b)

    has no such authority, but
    habitually maintains in the first mentioned State a stock of good or
    merchandise from which he regularly delivers goods or merchandise on
    behalf of the enterprise; or
    (c)

    manufactures or
    processes in
    that State for the enterprise goods or merchandise belonging to the
    enterprise.

  6. An insurance enterprise of a
    Contracting State shall, except with regard to reinsurance, be deemed
    to have a permanent establishment in the other Contracting State if it
    collects premiums in that other State or insures risks situated therein
    through an employee or through a representative who is not an agent of
    an independent status within the meaning of paragraph 7.

  7. An enterprise of a Contracting
    State shall not be deemed to have a permanent establishment in the
    other Contracting State merely because it carries on business in that
    other State through a broker, general commission agent or any other
    agent of an independent status, provided that such persons are
    acting in the ordinary course of their business. However, when the
    activities, of such an agent are devoted wholly or almost wholly on
    behalf of that enterprise or its associated enterprises, he will not be
    considered an agent of an independent status within the meaning of this
    paragraph.

  8. The fact that a company which
    is a
    resident of a Contracting State controls or is controlled by a company
    which is a resident of the other Contracting State, or which carries on
    business in that other State (whether through a permanent establishment
    or otherwise), shall not of itself constitute either company a
    permanent establishment of the other.

Article
6
INCOME FROM IMMOVABLE PROPERTY

  1. Income derived by a resident of
    a
    Contracting State from immovable property (including income from
    agriculture or forestry) situated in the other Contracting State may be
    taxed in that other State.

  2. The term “immovable property”
    shall have the meaning which it has under the law of the Contracting
    State in which the property in question is situated. The term shall in
    any case include property accessory to immovable property, livestock
    and equipment used in agriculture and forestry, rights to which the
    provisions of general law respecting landed property apply, usufruct of
    immovable property and rights to variable or fixed payments as
    considerations for the working of, or the rights to work, mineral
    deposits, sources and other natural resources; ships, boats and
    aircraft shall not be regarded as immovable property.

  3. The provisions of paragraph 1
    shall also apply to income derived from the direct use, letting, or use
    in any other form of immovable property.

  4. The provisions of paragraphs 1
    and
    3 shall also apply to the income from immovable property of an
    enterprise and to income from immovable property used for the
    performance of independent personal services.

Article
7
BUSINESS PROFITS

  1. The profits of an enterprise of
    a
    Contracting State shall be taxable only in that State unless the
    enterprise carries on business in the other Contracting State through a
    permanent establishment situated therein. If the enterprise carries on
    business as aforesaid, the profits of the enterprise may be taxed in
    the other State but only so much of them as is attributable to 
    (a) that permanent establishment; 
    (b) sales in that other State of goods or a merchandise of the same or
    similar kind as those sole through that permanent establishment; or (c)
    other business activities carried on (in)  that other State of
    same of similar kind as those effected through that permanent
    establishment.

  2. Subject to the provisions of
    paragraph 3, where an enterprise of a Contracting State carries on
    business in the other Contracting State through a permanent
    establishment situated therein, there shall in each Contracting State
    be attributed to that permanent establishment the profits which it
    might be expected to make if it were a distinct and separate enterprise
    engaged in the same or similar activities under  the same
    conditions and dealing wholly independently with the enterprise of
    which it is a permanent establishment.

  3. In determining the profits of a
    permanent establishment, there shall be allowed as deductions expenses
    which are incurred for the purposes of the business of the permanent
    establishment, including executive and general administrative expenses
    so incurred, whether in the State in which the permanent establishment
    is situated or elsewhere. However, no such deduction shall be allowed
    in respect of amounts, if any, paid (otherwise than towards
    reimbursement of actual expenses) by the permanent establishment to the
    head office of the enterprise or any of its other offices, by way of
    royalties, fees or other similar payments in return for the use of
    patents other rights, or by way of commission, for specific services
    performed or for management, or, except in the case of banking
    enterprise, by way of interest on moneys lent to the permanent
    establishment. Likewise, no account shall be taken, in the
    determination of the profits of a permanent establishment, for amounts
    charged, (otherwise than towards reimbursement of actual expenses), by
    the permanent establishment to the head office of the enterprise or any
    of its other offices, by way of royalties, fees or other similar
    payments in return for the use of patents or other rights, or by way of
    commission for specific services performed or, for management, or,
    except in the case of banking enterprise, by way of interest on moneys
    lent to the head office of the enterprise or any of its other offices.

  4. For the purpose of the
    preceding
    paragraphs, the profits to be attributed to the permanent establishment
    shall be determined by the same method year by year unless there is
    good and sufficient reason to the contrary.

  5. Where profits include items of
    income which are dealt with separately in other Articles of this
    Agreement, then the provisions of those Articles shall not be affected
    by the provisions of this Article.

  6. No profits shall be attributed
    to
    a permanent establishment by reason of the mere purchase by that
    permanent establishment of goods or merchandise for the enterprise.

Article
8
SHIPPING AND AIR TRANSPORT

  1. Profits derived by an
    enterprise
    of Contracting State from the operation of ships or aircraft in
    international traffic shall be taxable only in that State.

  2. The provisions of paragraph 1
    shall also apply to profits from the participation in a pool, a joint
    business or an international operating agency.

Article
9
ASSOCIATED ENTERPRISES

  1. Where

    1. an enterprise of a
      Contracting
      State participates directly or indirectly in the management, control or
      capital of an enterprise of the other Contracting State, or

    2. the same person participate
      directly or indirectly in the management, control or capital of an
      enterprise of a Contracting State and an enterprise of the other
      Contracting State, 
      and in either case conditions are made or imposed between the two
      enterprises in their commercial or financial relation which differ from
      those which would be made between independent enterprises, then any
      profits which would, but for those conditions, have accrued to one of
      the enterprises, but, by reason of those conditions, have not so
      accrued, may be included in the profits of that enterprise and taxed
      accordingly.

  2. Where a Contracting States
    includes in the profits of an enterprise of that State – and taxes
    accordingly – profits on which an enterprise of the other Contracting
    State has been charged to tax in that other State and the
    profits so included are profits which would have accrued to the
    enterprise of the firs-mentioned State if the conditions made between
    the two enterprises had been those which would have been made
     beetwen independent enterprises, then that other State shall
    make an appropriate adjustment to the amount of the tax charged therein
    on those profits. In determining such adjustment due regard shall be
    had to the other provisions of the Agreement and the competent
    authorities of the Contracting States shall if necessary consult each
    other.

  3. A Contracting State shall not
    change the profits of an enterprise in the circumstances referred to in
    paragraph 2 after the expiry of the time limits provided in its tax
    laws.

  4. The provisions of paragraph 2
    shall not apply in the case of tax fraud.

Article
10
DIVIDENDS

  1. Dividends paid by a company
    which
    is a resident of a Contracting State to a resident of the other
    Contracting State may be taxed in that other State.

  2. However, if the beneficial
    owner
    of the dividends is a resident of the other Contracting State, the tax
    charged by the first-mentioned State may not exceed 10 per cent of the
    gross amount of the dividends actually distributed. This paragraph
    shall not affect the taxation of the company in respect of the profits
    out of which the dividends are paid.

  3. The term “dividends” as used in
    this Article means income from shares, or other rights, not being
    debt-claims, participating in profits, as well as income from other
    corporate rights which is subjected to the same taxation treatment as
    income from shares by the laws of the State of which the company making
    the distribution is a resident.

  4. The provisions of paragraphs 1
    and
    2 shall not apply if the beneficial owner of the dividends, being a
    resident of a Contracting State, carries on business in the other
    Contracting State, of which the company paying the dividends is a
    resident, through a permanent establishment situated therein, or
    performs in that other State independent personal services from a fixed
    base situated therein, and the holding in respect of which the
    devidends are paid is effectively connected with such permanent
    establishment or fixed base. In such a case the provisions of Article 7
    or Article 14, as the case may be, shall apply.

Article
11
INTEREST

  1. Interest arising in a
    Contracting
    State and paid to a resident of the other Contracting State may be
    taxed in that other Contracting State if such resident is the
    beneficial owner of the interest.

  2. The rate of tax imposed by one
    of
    the Contracting State on interest derived from sources within that
    Contracting State and beneficially owned by a resident of the other
    Contracting State shall not exceed 10 percent of gross amount of the
    interest.

  3. Notwithstanding the provisions
    of
    paragraph 2, interest arising in a Contracting State and derived by the
    Government of the other Contracting State including local authorities
    thereof, a political subdivision, the Central Bank or any financial
    institution controlled by that Government, the capital of which is
    wholly owned by the Government of the other Contracting State, as may
    be agreed upon from time to time between the competent authorities of
    the Contracting State, shall be exempt from tax in the first-mentioned
    State.

  4. The term “interest” as used in
    this Article means income from debt-claims of every kind, whether or
    not secured by mortgage and whether or not carrying a right to
    participate in the debitor’s profits, and in particular, incom from
    government securities and income from bonds or debentures, including
    premiums and prizes attaching to such securities, bonds or debentures,
    as well as income assimilited to income from money lent.

  5. The provisions of paragraphs 1,
    and 2 shall not apply if the beneficial owner of the interest, being a
    resident of a Contracting State, carries on business in the other
    Contracting State in which the interest arises, through a permanent
    establishment situated therein, or performs in that other State
    independent personal services from a fixed base situated therein, and
    the debt-claim in respect of which the interest is paid is effectively
    connected with a) such permanent establishment or fixed base, or with
    b) business activities referred to under c) of paragraph 1 of Article
    7. In such case, the provisions of Article 7 or Article 14, as the case
    may be, shall apply.

  6. Interest shall be deemed to
    arise
    in a Contracting State when the payer is that State itself, a political
    subdivision, a local authority or a resident of that State. Where,
    however, the person paying the interest, whether he is a resident of a
    Contracting State or not, has in a Contracting State a permanent
    establishment or a fixed base in connection with which the indebtedness
    on which the interest is paid was incurred, and such interest is borne
    by such permanent establishment or fixed base, then such interest shall
    be deemed to arise in the State in which the permanent establishment or
    fixed base is situated.

  7. Where, by reason of a special
    relationship between the payer and the beneficial owner or between both
    of them and some other person, the amount of the interest, having
    regard to the debt-claim for which it is paid, exceeds the amount which
    would have been agreed upon by the payer and the beneficial owner in
    the absence of such relationship, the provisions, of this Article shall
    apply only to the last-mentioned amount. In such case, the excess part
    of the payments shall remain taxable according to the laws of each
    Contracting State, due regard being had to the other provisions of this
    Agreement.

Article
12
ROYALTIES

  1. Royalties arising in a
    Contracting
    State and paid to a resident of the other Contracting State may be
    taxed in that other Contracting State.

  2. The rate of tax imposed by one
    of
    Contracting State on royalties derived from sources within that
    Contracting State and beneficially owned by resident of the other
    Contracting State shall not exceed 10 percent of gross amount of the
    royalties described in paragraph 3.

  3. The term “royalties” as used in
    this Article means payments, whether periodical or not, and in whatever
    form or name or nomenclature to the extent to which they are made as
    consideration for:

    1. the use of, or the right to
      use, any copyright, patent, design or model, plan, secret formula or
      process, trade mark or other like property or right; or

    2. the use of, or right to
      use,
      any industrial, commercial, or scientific equipment; or

    3. the supply of scientific,
      technical, industrial, or commercial knowledge or information; or

    4. the supply of any assistance
      that is ancillary and subsidiary (to) any such property or right as
      mentioned in sub-paragraph (a), any such equipment as is mentioned in
      sub-paragraph (b), or any such knowledge or information as is mentioned
      in sub-paragraph (c); or

    5. the use of, or the right to
      use:

      (a)

      motion picture films; or
      (b)

      films or video for use
      in connection with television; or
      (c)

      tapes for use in
      connection with radio broadcasting; or

    6. total or partial
      forbearance
      in respect of the use or supply or any property or right referred to in
      this paragraph.

  4. The provisions of paragraphs 1
    and
    2 shall not apply if the beneficial owner of the royalties, being a
    resident of a Contracting State, carries on business in the other
    Contracting State in which the royalties arise, through a permanent
    establishment situated therein, or performs in that other State
    independent personal services from a fixed base situated therein, and
    the right or property in respect of which the royalties are paid is
    effectively connected with (a) such permanent establishment or fixed
    base, or with (b) business activities referred to under (c) of
    paragraph 1 of Article 7. In such case, the provisions of Article 7 or
    Article 14, as the case may be, shall apply.

  5. Royalties shall be deemed to
    arise
    in a Contracting State when the payer is that State itself, a local
    authority or a resident of that State. Where, however, the person
    paying the royalties, whether he is a resident of a Contracting State
    or not, has in a Contracting State a permanent establishment or a fixed
    base in connection with which the liability to pay the royalties was
    incurred, and such royalties are borne by such permanent establishment
    or fixed base, then such royalties shall be deemed to arise in the
    State in which the permanent establishment or fixed base is situated.

  6. Where, by reason of a special
    relationship between the payer and the beneficial owner or between both
    of them and some other person, the amount of the royalties, having
    regard to the use, right or information for which they are paid,
    exceeds the amount which would have been agreed upon by the payer and
    the beneficial owner in the absence of such relationship, the
    provisions of this Article shall apply only to the last-mentioned
    amount. In such case, the excess part of the payment shall remain
    taxable according to the laws of each Contracting State, due regard
    being had to the other provisions of this Agreement.

Article
13
CAPITAL GAINS

  1. Gains derived by a resident of a
    Contracting State from the alienation of immovable property referred to
    in Article 6 and situated in the other Contracting State may be taxed
    in that other State.

  2. Gains from the alienation of
    movable property forming part of the business property of a permanent
    establishment which an enterprise of a Contracting State has in the
    other Contracting State or of movable property pertaining to a fixed
    base available to a resident of a Contracting State in the other
    Contracting State for the purpose of performing independent personal
    services, including such gains from the alienation of such a permanent
    establishment (alone or with the whole enterprise) or of such fixed
    base, may be taxed in that other State

  3. Gains derived by an enterprise
    of a
    Contracting State from the alienation of ships or aircraft operated in
    international traffic or movable property pertaining to the operation
    of such ships or aircraft shall be taxable only in that State..

Gains from the alienation of any property other than that referred to
in the preceding paragraphs shall be taxable only in the Contracting
State where the gains arise.

Article
14
INDEPENDENT PERSONAL SERVICES

  1. Income derived by a resident of
    a
    Contracting State in respect of professional services or other
    activities of an independent character shall be taxable only in that
    State, unless he has a fixed base regularly available to him in the
    other Contracting State for the purpose of performing his activities or
    he is present in that other State for a period or periods exceeding in
    the aggregate 90 days within any twelve-month period. If he has such a
    fixed base or remains in that other State for the aforesaid period or
    periods, the income may be taxed in that other State but only so much
    of it as is attributable to that fixed base or is derived in that other
    State during the aforesaid period or periods.

  2. The term “professional services”
    includes especially independent scientific, literary, artistic,
    educational or teaching activities as well as the independent
    activities of physicians, lawyers, engineers, architects, dentists and
    accountants.

Article
15
DEPENDENT PERSONAL SERVICES

  1. Subject to the provisions of
    Articles 16, 18, 19 and 20, salaries, wages and other similar
    remuneration derived by a resident of a Contracting State in respect of
    an employment shall be taxable only in that State unless the employment
    is exercised in the other Contracting State. If the employment is so
    exercised, such remuneration as is arrived therefrom may be taxed in
    that other State.

  2. Notwithstanding the provisions
    of
    paragraph 1, remuneration derived by a resident of a Contracting State
    in respect of an employment exercised in the other Contracting State
    shall be taxable only in the first-mentioned State if:

    (a)

    the recipient is present in
    that other State for a period or periods not exceeding in the aggregate
    183 days within any twelve-month period; and
    (b)

    the remuneration is paid
    by, or on behalf of, an employer who is not a resident of the other
    State; and
    (c)

    the remuneration is not borne
    by a permanent establishment or a fixed base which the employer has in
    the other State.

  3. Notwithstanding the preceding
    provisions of this Article, remuneration derived in respect of an
    employment exercised aboard a ship or aircraft operated in
    international traffic by an enterprise of a Contracting State shall be
    taxable only in that State.

Article
16
DIRECTORS FEES

Directors’
fees and other similar
payments derived by a resident of a Contracting State in his capacity
as a member of the board of directors or any other similar organ of a
company which is a resident of the other Contracting State may be taxed
in that other Contracting State.

Article
17
ARTISTES AND ATHLETES

  1. Notwithstanding the provisions
    of
    Articles 14 and 15, income derived by a resident of a Contracting State
    as an entertainer, such as a theatre, motion picture, radio or
    television artiste, or a musician, or as an athlete, from his personal
    activities as such exercised in the other Contracting State, may be
    taxed in that other State.

  2. Where income in respect of
    personal
    activities exercised by an entertainer or an athlete in his capacity as
    such accrues not to the entertainer or athlete himself but to another
    person, that income may, notwithstanding the provisions of Articles 7,
    14 and 15, be taxed in the Contracting State in which the activities of
    the entertainer or athlete are exercised.

  3. Notwithstanding the provisions
    of
    paragraphs 1 and 2, income derived from activities referred to in
    paragraph 1 performed under a cultural agreement or arrangement between
    the Contracting States shall be exempt from tax in the Contracting
    State in which the activities are exercised if the visit to that State
    is wholly or substantially supported by funds of one or both of the
    Contracting States, a local authority or public institution thereof.

Article
18
PENSIONS AND ANNUITIES

  1. Subject to the provisions of
    paragraph 2 of Article 19, any pension or other similar remuneration
    paid to a resident of one of the Contracting States from a source in
    that other Contracting State in consideration of past employment or
    services in the other Contracting State and any annuity paid to such a
    resident from such a source may be taxed in that other State.

  2. The “annuity” means a stated sum
    payable periodically at stated times during life or during a specified
    or ascertainable period of time under an obligation to make the
    payments in return for adequate and full consideration in money or
    money’s worth.

Article
19
GOVERNMENT SERVICE

1. (a)

Remuneration, other than a
pension, paid by a Contracting State or a political subdivision or a
local authority thereof to an individual in respect of services
rendered to that State or subdivision or authority shall be taxable
only in that State.
(b)

However, such remuneration shall
be taxable only in the other Contracting State if the services are
rendered in that other State and the individual is a resident of that
State who:

(i)

is a national of that State; or
(ii)

did not become a resident of that
State solely for the purpose of rendering the services.
2. (a)

Any pension paid by, or out of
funds created by, a Contracting State or a political subdivision or a
local authority thereof to an individual in respect of services
rendered to that State or subdivision or local authority thereof shall
be taxable only in that State.
(b)

However, such pension shall be
taxable only in the other Contracting State if the individual is a
resident of, and a national of, that other State.
3.

The provisions of Articles 15, 16
and 18 shall apply to remuneration, and to pensions, in respect of
services rendered in connection with a business carried on by a
Contacting State or a political subdivision or a local authority
thereof.

Article
20
TEACHERS AND RESEARCHERS

An
individual who is immediately
before visiting a Contracting State a resident of the other Contracting
State and who, at the invitation of the Government of the
first-mentioned Contracting State or of a University, college, school,
museum or other cultural institution in that first-mentioned
Contracting State or under an official programme of cultural exchange,
is present in that Contracting State for a period not exceeding two
consecutive years solely for the purpose of teaching, giving lectures
or carrying out research at such institution, shall be exempt from tax
in that Contracting State on his remuneration for such activity,
provided that payment of such remuneration is derived by him from
outside that Contracting State.

Article
21
STUDENTS AND TRAINEES

  1. Payments which a student or
    business trainee who is or was immediately before visiting a
    Contracting State a resident of the other Contracting State and who is
    present in the first-mentioned Contracting State solely for the purpose
    of his maintenance, education or training shall not be taxed in that
    Contracting State, provided that such payments arise from sources
    outside that Contracting State.

  2. In respect of grants,
    scholarships
    and remuneration from employment not covered by paragraph 1, a student
    or business trainee described in paragraph 1 shall, in addition, be
    entitled during such education or training to the same exemption,
    reliefs or reductions in respect of taxes available to residents of the
    Contracting State which he is visiting

Article
22
OTHER INCOME

Items of income of a resident of a
Contracting State, which are not expressly mentioned in the foregoing
Articles of this Agreement shall be taxable only in that State except
that, if such income is derived from sources within the other
Contracting State, it may also be taxed in that other State

Article
23
METHOD FOR ELIMINATION OF DOUBLE TAXATION

Where
a resident of a Contracting
State derives income from the other Contracting State, the amount of
tax on that income payable in that other Contracting State in
accordance with the provisions of this Agreement, may be credited
against the tax levied in the first- mentioned Contracting State
imposed on that resident. The amount of credit, however, shall not
exceed the amount of tax in the first- mentioned Contracting State on
that income computed in accordance with its taxation laws and
regulations.

Article
24
NON-DISCRIMINATION

  1. Nationals of a Contracting State
    shall not be subjected in the other Contracting State to any taxation
    or any requirement connected therewith which is other or more
    burdensome than the taxation and connected requirements to which
    nationals of that other State in the same circumstances are or may be
    subjected.

  2. The taxation on a permanent
    establishment which an enterprise of a Contracting State has in the
    other Contracting State shall not be less favourably levied in that
    other State than the taxation levied on enterprise of that other State
    carrying on the same activities. This provision shall not be construed
    as obliging a Contracting State to grant to residents of the other
    Contracting State any personal allowances, reliefs and reductions for
    taxation purposes on account of civil status or family responsibilities
    which it grants to its own residents

  3. Enterprises of a Contracting
    State,
    the capital of which is wholly or partly owned or controlled, directly
    or indirectly, by one or more residents of the other Contracting State,
    shall not be subjected in the first-mentioned State to any taxation or
    any requirement connected therewith which is other or more burdensome
    than the taxation and connected requirements to which other similar
    enterprises of the first-mentioned State are or may be subjected

  4. Except where the provisions of
    paragraph 1 of Article 9, paragraph 7 of Article 11, or of paragraph 6
    of Article 12 apply, interest, royalties and other disbursements paid
    by an enterprise of a Contracting State to a resident of the other
    Contracting State shall, for the purpose of determining the taxable
    profits of such enterprise, be deductible under the same conditions as
    if they had been paid to a resident of the first-mentioned State.

  5. In this Article the term
    “taxation”
    means taxes which are the subject of this Agreement.

Article
25
MUTUAL AGREEMENT PROCEDURE

  1. Where a person considers that
    the
    actions of one or both of the Contracting States result or will result
    for him in taxation not in accordance with the provisions of this
    Agreement, he may, irrespective of the remedies provided by the
    domestic law of those States, present his case to the competent
    authority of the Contracting State of which he is a resident or, if his
    case comes under paragraph 1 of Article 24, to that of the Contracting
    State of which he is a national. The case must be presented within two
    years from the first notification of the action resulting in taxation
    not in accordance with the provisions of the Agreement.

  2. The competent authority shall
    endeavour, if the objection appears to it to be justified and if it is
    not itself able to arrive at a satisfactory solution, to resolve the
    case by mutual agreement with the competent authority of the other
    Contracting State, with a view to the avoidance of taxation which is
    not in accordance with this Agreement.

  3. The competent authorities of the
    Contracting States shall endeavour to
    resolve by mutual agreement any difficulties or doubts arising as to
    the interpretation or application of the Agreement. They may also
    consult together for the elimination of double taxation in cases not
    provided for in the Agreement.
     

  4. The competent authorities of the
    Contracting States may communicate with each other directly for the
    purpose of reaching an agreement in the sense of the preceding
    paragraphs. The competent authorities, through consultations, shall
    develop appropriate bilateral procedures, conditions, methods and
    techniques for the implementation of the mutual agreement procedure
    provided for in this Article.

Article
26
EXCHANGE OF INFORMATION

  1. The competent authorities of the
    Contracting States shall exchange such information as is necessary for
    carrying out the provisions of this Agreement or of the domestic laws
    of the Contracting States concerning taxes covered by the Agreement,
    insofar as the taxation thereunder is not contrary to this Agreement,
    in particular for the prevention of fraud or evasion of such taxes. The
    exchange of information is not restricted by Article 1. Any information
    received by a Contracting State shall be treated as secret in the same
    manner as information obtained under the domestic laws of that State.
    However, if the information is originally regarded as secret in the
    transmitting State it shall be disclosed only to persons or authorities
    (including courts and administrative bodies) involved in the assessment
    or collection of, the enforcement or prosecution in respect of, or the
    determination of appeals in relation to, the taxes which are the
    subject of the Agreement. Such persons or authorities shall use the
    information only for such purposes but may disclose the information in
    public court proceedings or in judicial decisions.

  2. In no case shall the provisions
    of
    paragraph 1 be construed so as to impose on a Contracting State the
    obligation:

    (a) to
    carry out
    administrative measures at variance with the laws and the
    administrative practice of that or of the other Contracting State;
    (b)

    to supply information which
    is not obtainable under the laws or in the normal course of the
    administration of that or of the other Contracting State;
    (c)

    to supply information which
    would disclose any trade, business, industrial, commercial or
    professional secret or trade process, or information, the disclosure of
    which would be contrary to public policy (ordre public).

Article
27
DIPLOMATIC AND CONSULAR OFFICERS

Nothing
in this Agreement shall
affect the fiscal privileges of diplomatic agents or consular officers
under the general rules of international law or under the provisions of
special agreements.

Article
28
ASSISTANCE IN COLLECTION

  1. Each of the Contracting States
    shall endeavour to collect on behalf of the other Contracting State
    such taxes imposed by that other Contracting State as will ensure that
    any exemption or reduced rate of tax granted under this Agreement by
    that other Contracting State shall not be enjoyed by persons not
    entitled to such benefits. The competent authorities of the Contracting
    States may consult together for the purpose of giving effect to this
    Article.

  2. In no case shall this Article be
    construed so as to impose upon a Contracting State the obligation to
    carry out administrative measures at variance with the regulations and
    practices of either Contracting State or which would be contrary to the
    first-mentioned Contracting State’s sovereignty, security, or public
    policy.

Article
29
ENTRY INTO FORCE

  1. This Agreement shall enter into
    force on the later of the dates on which the respective Governments may
    notify each other in writing that the formalities constitutionally
    required in their respective States have been complied with.

  2. This Agreement shall have
    effect:

    1. in respect of tax withheld
      at
      the source to income derived on or after 1 January in the year next
      following that in which the Agreement enters into force; and

    2. in respect of other taxes on
      income for taxable years beginning on or after 1 January in the year
      next following that in which the Agreement enters into force.

Article
30
TERMINATION

This
Agreement shall remain in
force until terminated by a Contracting State. Either Contracting State
may terminate the Agreement, through diplomatic channels, by giving
written notice of termination on or before the thirtieth day of June of
any calendar year following after the period of five years from the
year in which the Agreement enters into force.

In such event, the Agreement shall
cease to have effect:

  1. in respect of taxes withheld at
    source to income derived on or after 1 January in the year next
    following that in which the notice of termination is given;

  2. in respect of other taxes on
    income
    for taxable years beginning on or after 1 January in the year next
    following that in which the notice of termination is given.

In witness whereof the undersigned,
being duly authorized thereto, have signed this Agreement.

DONE in duplicate at Amman this day
twelfth of November 1996.

Done in duplicate at Amman this
twelfth
day of November 1996 in the Indonesian, Arabic and English languages.
All texts being equally authentic. In case of any divergency of
interpretation, the English text shall prevail.

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