Singapore

1.

This Agreement shall apply to taxes on income imposed on
behalf of a Contracting State or of its political subpisions 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, taxes on the total amounts of wages or salaries paid
by enterprises, as well as taxes on capital
appreciation.

3.

The existing taxes to which this Agreement shall apply
are: 

4.

This Agreement shall apply also to any identical or
substantially similar taxes that 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 significant
changes that have been made in their taxation
laws.

1.

For the purposes of this Agreement, unless the context
otherwise requires :

2.

As regards the application of the Agreement at any time by a
Contracting State, any term not defined therein shall, unless the context otherwise
requires, have the meaning that it has at that time under the law of that State for
the purposes of the taxes to which the Agreement applies, any meaning under the
applicable tax laws of that State prevailing over a meaning given to the term under
other laws of that State.

1.

For the purposes of this Agreement, the term “resident of a
Contracting State” means any person who, under the laws of that State, is liable to
tax therein by reason of his domicile, residence, place of incorporation, place of
management or any other criterion of a similar nature, and also includes that State
and any political subpision, local authority or statutory body
thereof.

2.

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

3.

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

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:

3.

The term “permanent establishment” shall not be deemed to
include:

4.

An enterprise of a Contracting State shall be deemed to have
a permanent establishment in the other Contracting State if it carries on supervisory
activities in that other State for more than 6 months in connection with a
construction, installation or assembly project which is being undertaken in that other
State.

5.

A person acting in one of the Contracting States for or on
behalf of an enterprise of the other Contracting State – other than an agent of an
independent status to whom paragraph 7 of this Article applies – shall be deemed to be
a permanent establishment in the first-mentioned State, 
if:

6.

Notwithstanding the preceding provisions of this Article, an
insurance enterprise of a Contracting State shall, except in regard to re-insurance,
be deemed to have a permanent establishment in the other Contracting State if it
collects premiums in the territory of that other State or insures risks situated
therein through a person other than an agent of an independent status to whom
paragraph 7 applies.

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, where 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 the enterprise, he shall 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 make either company a
permanent establishment of the other.

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 consideration for the working of,
or the right to work, mineral deposits, sources and other natural resources: ships and
aircraft shall not be regarded as immovable 
property.

3.

The provisions of paragraph 1 shall 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.

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 that permanent
establishment.

2.

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 or
similar 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 including executive and general
administrative expenses, which would be deductible if the permanent establishment were
an independent enterprise, insofar as they are reasonably allocable to the permanent
establishment, whether incurred in the State in which the permanent establishment is
situated or elsewhere.

4.

If the information available to the competent authority is
inadequate to determine the profits to be attributed to the permanent establishment of
an enterprise, nothing in this Article shall affect the application of any law of that
State relating to the determination of the tax liability of a person by the exercise
of a discretion or the making of an estimate by the competent authority, provided that
the law shall be applied, so far as the information available to the competent
authority permits, in accordance with the principle of this
Article.

5.

For the purposes of the preceding paragraphs, the profits to
he 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.

6.

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.

7.

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.

1.

Income derived by an enterprise of a Contracting State from
the operation of aircraft in international traffic shall be taxable only in that
Contracting State.

2.

Income derived by an enterprise of a Contracting State from
the operation of ships in international traffic may be taxed in the other Contracting
State, but the tax imposed in that other State shall be reduced by an amount equal to
50% thereof.

3.

The provisions of paragraphs 1 and 2 shall also apply to the
share of the income from the operation of ships or aircraft derived by an enterprise
of a Contracting State through participation in a pool, a joint business or an
international operating agency.

1.

Where

and in either case conditions are made or imposed between
the two enterprises in their commercial or financial relations 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 State 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
first-mentioned State if the conditions made between the two enterprises had been
those which would have been made between 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 this Agreement and the competent authorities of the Contracting States
shall if necessary consult each other.

3.

The provisions of paragraph 2 shall not apply where judicial
or other legal proceedings have resulted in a final ruling that by actions giving rise
to an adjustment of profits under paragraph 1, one of the enterprises concerned is
liable to penalty with respect to fraud, gross negligence or wilful
default.

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, such pidends may be taxed in the Contracting State
of which the company paying the pidends is a resident, and according to the law of
that State, but if the recipient is the beneficial owner of the pidends the tax so
charged shall not exceed:

The provisions of this paragraph shall not affect the
taxation of the company on the profits out of which the pidends are
paid.

3.

The term “pidends” as used in this Article means income from
shares, “jouissance” shares or “jouissance” rights, mining shares, founders 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 pidends, being a resident of a Contracting State, carries on
business in the other Contracting State of which the company paying the pidends 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 pidends are paid is effectively connected with such
permanent establishment or fixed base. In such case the provisions of Article 7 or
Article 14, as the case may be, shall apply.

5.

Where a company which is a resident of a Contracting State
derives profits or income from the other Contracting State, that other State may not
impose any tax on the pidends paid by the company, except insofar as such pidends are
paid to a resident of that other State or insofar as the holding in respect of which
the pidends are paid is effectively connected with a permanent establishment or a
fixed base situated in that other State, nor subject the companys undistributed
profits to a tax on the companys undistributed profits, even if the pidends paid or
the undistributed profits consist wholly or partly of profits or income arising in
such other State.

6.

Notwithstanding any other provisions of this Agreement,
where a company which is a resident of a Contracting State has a permanent
establishment in the other Contracting State, the profits of the permanent
establishment may be subjected to an additional tax in that other State in accordance
with its law, but the additional tax so charged shall not exceed 10 per cent of the
amount of such profits after deducting therefrom income tax and other taxes on income
imposed thereon in that other State.

7.

The provisions of paragraph 6 of this Article shaII not
affect the provision contained in any production sharing contracts relating to oil and
gas, and contract of works for other mining sectors, concluded by a Contracting State
or its relevant state oil and gas company or any other entity thereof with a person
who is a resident of the other Contracting
State.

1.

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

2.

However, such interest may also be taxed in the Contracting
State in which it arises and according to the laws of that State, but if the
beneficial owner of the interest is a resident of the other Contracting State, the tax
so charged shall not exceed 10 per cent of the gross amount of the
interest.

3.

Notwithstanding the provisions of paragraph 2, the
Government of a Contracting State shall be exempt from tax in the other Contracting
State in respect of interest derived from that other
State.

4.

For the purposes of paragraph 3, the term
“Government”:

5.

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 debtors profits, and in particular, income from
government securities and income from bonds or debentures, including premiums and
prizes attaching to such securities, bonds or debentures. Penalty charges for late
payment shall not be regarded as interest for the purpose of this
Article.

6.

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 mises through a
permanent establishment situated therein, or perform 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 such permanent establishment
or fixed base. In such case the provisions of Article 7 or Article 14, as the case may
be, shall apply.

7.

Interest shall be deemed to arise in a Contracting State
when the payer is 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.

8.

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.

1.

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

2.

However, such royalties may also be taxed in the Contracting
State in which they arise and according to the laws of that State, but if the
beneficial owner of the royalties is a resident of the other Contracting State, the
tax so charged shall not exceed:

3.

The term “royalties” as used in this Article means payments
of any kind received as a consideration:

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 such permanent
establishment or fixed base. 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 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 payments shall
remain taxable according to the laws of each Contracting State, due regard being had
to the other provisions of this Agreement.

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 a resident 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.

4.

Gains derived by a resident of a Contracting State from the
alienation of shares, other than shares traded on an approved stock exchange, deriving
more than 50 per cent of their value directly or indirectly from immovable property,
as defined in Article 6, situated in the other Contracting State may be taxed in that
other State if the alienator owned at least 50 per cent of the total issued shares of
the company whose shares are alienated. However, this paragraph shall not apply to
gains derived from the alienation of shares deriving value from immovable property in
which the company carries on its business and to gains derived from the alienation of
shares alienated or exchanged in the framework of a reorganization of a company, a
merger, a scission or a similar operation.

5.

Gains from the alienation of shares in a company which is a
resident of Indonesia and traded on the Indonesia Stock Exchange may be taxed in
Indonesia in accordance with the Minister of Finance Decree No. 282/KMK.04/1997 (The
Implementation of Withholding Tax on Income Derived from the Alienation of Shares on
Stock Exchange), as may be amended from time to
time.

6.

Gains from the alienation of any property, other than that
referred to in paragraphs 1, 2, 3, 4 and 5 shall be taxable only in the Contracting
State of which the alienator is a resident.

1.

Income derived by an inpidual who is 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 except in the following
circumstances, when such income may also be taxed in the other Contracting
State:

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.

1.

Subject to the provisions of Articles 16, 18, 19 and 21,
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 derived 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:

3.

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

1.

Notwithstanding the provisions of Articles 14 and 15, income
derived by a resident of a Contracting State as an entertainer, such as a theater,
motion picture, radio or television artiste, or a musician, or as a sportsperson, from
that residents 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 a sportsperson acting as such accrues not to the entertainer or
sportsperson but to another person, that income may, notwithstanding the provisions of
Articles 14 and 15, be taxed in the Contracting State in which the activities of the
entertainer or sportsperson are exercised.

3.

The provisions of paragraphs 1 and 2 shall not apply to
income derived from activities performed in a Contracting State by entertainers or
sports persons if the visit to that State is wholly or mainly supported by public
funds of one or both of the Contracting States or political subpisions, local
authorities or statutory bodies thereof. In such a case, the income is taxable only in
the Contracting State in which the entertainer or the sportsperson is a
resident.

1.

Subject to the provisions of paragraph 2 of Article 19,
pensions and other similar remuneration arising in a Contracting State and paid to a
resident of the other Contracting State in consideration of past employment may be
taxable in the first-mentioned State.

2.

Notwithstanding the provision of paragraph 1, pensions paid
and other payments made under a public scheme which is part of the social security
system of a Contracting State or a political subpision or a local authority thereof
shall be taxable only in that State.

1.

2.

3.

The provisions of Articles 15, 16, 17 and 18 shall apply to
salaries, wages, pensions, and other similar remuneration in respect of services
rendered in connection with a business carried on by a Contracting State or a
political subpision, a local authority or a statutory body
thereof.

1.

An inpidual, who is a resident of a Contracting State
immediately before making a visit to the other Contracting State and who, at the
invitation of the Government of the other Contracting State, visits that other
Contracting State for the first time for a period not exceeding two years solely for
the purpose of teaching or research or both at an institution, shall be exempt from
tax in that other Contracting State on any remuneration received for such teaching or
research which is subject to tax in the first-mentioned Contracting
State.

2.

This Article shall not apply to income from teaching or
research if such teaching or research is undertaken not in the public interest but
primarily for the private benefit of a specific person or
persons.

1.

Items of income of a resident of a Contracting State,
wherever arising, not dealt with in the foregoing Articles of this Agreement shall be
taxable only in that State.

2.

The provisions of paragraph 1 shall not apply to income,
other than income from immovable property as defined in paragraph 2 of Article 6, if
the recipient of such income, being a resident of a Contracting State, carries on
business in the other Contracting State 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 income is paid
is effectively connected with such permanent establishment or fixed base. In such case
the provisions of Article 7 or Article 14, as the case may be, shall
apply.

3.

Notwithstanding the provisions of paragraphs 1 and 2, items
of income of a resident of a Contracting State not dealt with in the foregoing
Articles of this Agreement and arising in the other Contracting State may also be
taxed in that other State.

1.

In Indonesia, double taxation shall be avoided as
follows:

2.

In Singapore, double taxation shall be avoided as
follows:
Where a resident of Singapore derives income from Indonesia which, in accordance with
the provisions of this Agreement, may be taxed in Indonesia, Singapore shall, subject
to its laws regarding the allowance as a credit against Singapore tax of tax payable
in any country other than Singapore, allow the Indonesian tax paid, whether directly
or by deduction, as a credit against the Singapore tax payable on the income of that
resident. Where such income is a pidend paid by a company which is a resident of
Indonesia to a resident of Singapore which is a company owning directly or indirectly
not less than 10 per cent of the share capital of the first-mentioned company, the
credit shall take into account the Indonesian tax paid by that company on the portion
of its profits out of which the pidend is
paid.

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, in particular with
respect to residence, 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
favorably levied in that other State than the taxation levied on enterprises 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.

Where a Contracting State grants tax incentives to its
nationals designed to promote economic or social development in accordance with its
national policy and criteria, it shall not be construed as discrimination under this
Article.

5.

The provisions of this Article shall apply only to taxes
covered by Article 2 of this Agreement.

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. The case must be presented within
three 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 the Agreement. Any agreement reached shall be implemented
notwithstanding any time limits in the domestic law of the Contracting
States.

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.

1.

The competent authorities of the Contracting States shall
exchange such information as is foreseeably relevant for carrying out the provisions
of this Agreement or to the administration or enforcement of the domestic laws
concerning taxes of every kind and description imposed on behalf of the Contracting
States, or of their political subpisions or local authorities, insofar as the taxation
thereunder is not contrary to the Agreement. The exchange of information is not
restricted by Articles 1 and 2.

2.

Any information received under paragraph 1 by a Contracting
State shall be treated as secret in the same manner as information obtained under the
domestic laws of that State and shall be disclosed only to persons or authorities
(including courts and administrative bodies) concerned with the assessment or
collection of, the enforcement or prosecution in respect of, the determination of
appeals in relation to the taxes referred to in paragraph 1, or the oversight of the
above. Such persons or authorities shall use the information only for such purposes.
They may disclose the information in public court proceedings or in judicial
decisions. Notwithstanding the foregoing, information received by a Contracting State
may be used for other purposes when such information may be used for such other
purposes under the laws of both States and the competent authority of the supplying
State authorizes such use.

3.

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

4.

If information is requested by a Contracting State in
accordance with this Article, the other Contracting State shall use its information
gathering measures to obtain the requested information, even though that other State
may not need such information for its own tax purposes. The obligation contained in
the preceding sentence is subject to the limitations of paragraph 3 but in no case
shall such limitations be construed to permit a Contracting State to decline to supply
information solely because it has no domestic interest in such
information.

5.

In no case shall the provisions of paragraph 3 be construed
to permit a Contracting State to decline to supply information solely because the
information is held by a bank, other financial institution, nominee or person acting
in an agency or a fiduciary capacity or because it relates to ownership interests in a
person.

1.

Each Contracting State shall notify the other in writing
through diplomatic channels of the completion of the procedures required by its law
for the bringing into force of this
Agreement.

2.

The Agreement shall enter into force on the date of the
later of these notifications and its provisions shall have
effect:

3.

Upon its entry into force, this Agreement substitutes and
supersedes the Agreement between the Republic of Indonesia and the Republic of
Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion
with respect to Taxes on Income, with Protocol, done at Singapore on 8 May 1990, and
therefore the Agreement shall cease to have effect for all cases covered by this
Agreement as from the date on which the provisions of this Agreement commence to have
effect. With this Agreement, the understanding on paragraphs (b) and (c) of the
Exchange of Notes dated 8 May 1990 shall remain in force for both Contracting
States.

(a)

in lndonesian:

(b)

in Singapore:

FOR THE GOVERNMENT OF THE
REPUBLIC OF INDONESIA
 

SRI MULYANI INDRAWATI
MINISTER OF FINANCE

FOR THE GOVERNMENT OF THE
REPUBLIC OF SINGAPORE
 

INDRANEE RAJAH SECOND
MINISTER FOR FINANCE