{"id":455,"date":"2025-10-01T03:13:41","date_gmt":"2025-10-01T03:13:41","guid":{"rendered":"https:\/\/whimsical-pyramid.localsite.io\/?p=455"},"modified":"2025-10-01T03:13:41","modified_gmt":"2025-10-01T03:13:41","slug":"new-zealand","status":"publish","type":"post","link":"https:\/\/investinasia.id\/education\/tax-treaty\/new-zealand\/","title":{"rendered":"New Zealand"},"content":{"rendered":"
\n
\n

AGREEMENT BETWEEN
\n THE GOVERNMENT OF THE REPUBLIC OF INDONESIA
\n AND
\n THE GOVERNMENT OF NEW ZEALAND<\/b><\/p>\n


\n <\/span><\/p>\n

FOR<\/span>
\n THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL
\n EVASION WITH RESPECT TO TAXES ON INCOME<\/b><\/p>\n

Article 1
\n PERSONAL SCOPE<\/b><\/p>\n

This agreement shall apply to
\n persons who are residents of one or both of the Contracting States.<\/div>\n

Article 2
\n TAXES COVERED<\/b><\/p>\n

    \n
  1. \n

    The existing taxes to which the
    \n Agreement shall apply are :\n <\/p>\n\n\n\n\n\n\n\n
    (a)<\/td>\nin New Zealand :<\/td>\n<\/tr>\n
    (i)\n <\/td>\nthe
    \n income tax; and<\/td>\n<\/tr>\n
    (ii)\n <\/td>\nthe
    \n excess retention tax,<\/td>\n<\/tr>\n
    (hereinafter
    \n referred to as “New Zealand tax”);<\/td>\n<\/tr>\n
    (b)<\/td>\nin Indonesia :
    \n the income tax (pajak-penghasilan),
    \n (hereinafter referred to as “Indonesian tax”).<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

    \n<\/li>\n

  2. \n

    The Agreement shall apply also
    \n to
    \n any identical or substantially similar taxes, which are imposed after
    \n the date of signature of the Agreement in addition to, or in place of,
    \n the existing taxes. The competent authorities of the Contracting States
    \n shall notify each other of any significant changes, which have been
    \n made in their respective taxation laws.  <\/p>\n<\/li>\n<\/ol>\n

    Article 3
    \n GENERAL DEFINITIONS<\/b><\/p>\n

      \n
    1. \n

      For the purposes of this
      \n Agreement,
      \n unless the context otherwise requires:\n <\/p>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
      (a)\n <\/td>\n(i)<\/td>\n\n

      the term “New Zealand” means the
      \n territory of New
      \n Zealand but does not include Tokelau or the Associated Self Governing
      \n State of the Cook Island and Niue; it also includes any area beyond the
      \n territorial sea which by New Zealand legislation and in accordance with
      \n international law has been or may hereafter be, designated as an area
      \n in which the rights of New Zealand with respect to natural resources
      \n may be exercised;<\/p>\n<\/td>\n<\/tr>\n

      (ii)<\/td>\n\n

      the term “Indonesia” comprises the
      \n territory of the
      \n Republic of Indonesia as defined in its laws and the adjacent areas
      \n over which the Republic of Indonesia has sovereign rights or
      \n jurisdiction in accordance with the provisions of the United Nations
      \n Convention on the Law of the Sea, 1982; <\/p>\n<\/td>\n<\/tr>\n

      (b)<\/td>\n\n

      the term “a Contracting State” and “the
      \n other
      \n Contracting State” mean New Zealand or Indonesia as the context
      \n requires; <\/p>\n<\/td>\n<\/tr>\n

      (c)<\/td>\n\n

      the term “person” includes an
      \n individual, a company
      \n and any other body of persons; <\/p>\n<\/td>\n<\/tr>\n

      (d)<\/td>\n\n

      tthe term “company” means any body
      \n corporate or any
      \n entity which is treated as a body corporate for tax purposes;<\/p>\n<\/td>\n<\/tr>\n

      (e)<\/td>\n\n

      the terms ” enterprise of a Contracting
      \n State” and
      \n “enterprise of the other Contracting State” mean respectively and
      \n enterprise carried on by a resident of a Contracting State and an
      \n enterprise carried on by resident of the other Contracting
      \n State; <\/p>\n<\/td>\n<\/tr>\n

      (f)<\/td>\n\n

      the term “national” means: <\/p>\n<\/td>\n<\/tr>\n

      (i)\n <\/td>\n\n

      in respect of New Zealand, any
      \n individual possessing
      \n citizenship of New Zealand and any legal person, partnership or
      \n association deriving its status as such from the law in force in New
      \n Zealand; <\/p>\n<\/td>\n<\/tr>\n

      (ii)\n <\/td>\n\n

      in respect of Indonesia, any individual
      \n possessing
      \n the nationality of Indonesia and any legal person, partnership or
      \n association deriving its status as such from the law in force in
      \n Indonesia; <\/p>\n<\/td>\n<\/tr>\n

      (g)<\/td>\n\n

      the term “international traffic” means
      \n any transport
      \n by a ship or aircraft operated by an enterprise of a Contracting State,
      \n except when the ship or aircraft is operated solely between places in
      \n the other Contracting State;<\/p>\n<\/td>\n<\/tr>\n

      (h)<\/td>\n\n

      the term “competent authority” means :\n <\/p>\n<\/td>\n<\/tr>\n

      (i)\n <\/td>\n\n

      in the case of New Zealand, the
      \n Commissioner of
      \n Inland Revenue or his authorized representative;<\/p>\n<\/td>\n<\/tr>\n

      (ii)\n <\/td>\n\n

      in the case of Indonesia, the Minister
      \n of Finance or
      \n his authorized representative.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

      \n<\/li>\n

    2. \n

      In the Agreement, the term “New
      \n Zealand tax” and “Indonesian tax” do not include any charge imposed as
      \n a penalty or interest under the law of either Contracting State
      \n relating to the taxes to which the Agreement applies.<\/p>\n<\/li>\n

    3. \n

      As regards the application of
      \n the
      \n Agreement by a Contracting State, any term not defined therein shall,
      \n unless the context otherwise requires, have the meaning which it has
      \n under the laws of that State concerning the taxes to which the
      \n Agreement applies. <\/p>\n<\/li>\n<\/ol>\n

      Article 4
      \n RESIDENT<\/b><\/p>\n

        \n
      1. \n

        For the purposes of this
        \n Agreement,
        \n the term “resident of a Contracting State” means any person who, under
        \n the law of that Contracting State, is liable to tax herein by reason of
        \n this domicile, residence, place of management or any other criterion of
        \n similar nature. <\/p>\n<\/li>\n

      2. \n

        Whereby reason of the provisions
        \n of
        \n paragraph 1 an individual is a resident of both Contracting States,
        \n then this status shall be determined as follows:\n <\/p>\n\n\n\n\n\n
        (a)<\/td>\n\n

        he shall be deemed to be a resident of
        \n the State in
        \n which he has a permanent home available to him; if he has a permanent
        \n home available to him in both States, he shall be deemed to be a
        \n resident of the State with his personal and economic relations are
        \n closer (centre of vital interests);<\/p>\n<\/td>\n<\/tr>\n

        (b)<\/td>\n\n

        if the State in which he has his centre
        \n of vital
        \n interests cannot be determined, or if he has not a permanent home
        \n available to him in either State, he shall be deemed to be resident of
        \n the State in which he has an habitual abode; <\/p>\n<\/td>\n<\/tr>\n

        (c)<\/td>\n\n

        if he has a habitual abode in both
        \n States or in
        \n neither of them, the competent authorities of the Contracting State
        \n shall endeavour to settle the question by mutual agreement.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

        \n<\/li>\n

      3. \n

        Where, by reason of the
        \n provisions
        \n of paragraph 1, a person other than an individual is a resident of both
        \n Contracting States, the competent authorities of the Contracting State
        \n shall endeavour to settle the question by mutual agreement having
        \n regard to its day management, the place where it is incorporated or
        \n otherwise constituted and any other relevant factors. <\/p>\n<\/li>\n<\/ol>\n

        Article 5
        \n PERMANENT ESTABLISHMENT<\/b><\/p>\n

          \n
        1. \n

          For the purpose of this
          \n Agreement,
          \n the term “permanent establishment” means a fixed place of business
          \n through which the business of an enterprise is wholly or partly carried
          \n on. <\/p>\n<\/li>\n

        2. \n

          The term “permanent
          \n establishment”
          \n includes especially:\n <\/p>\n\n\n\n\n\n\n\n\n
          (a)<\/td>\na
          \n place of management;<\/td>\n<\/tr>\n
          (b)<\/td>\na
          \n branch;<\/td>\n<\/tr>\n
          (c)<\/td>\nan
          \n office;<\/td>\n<\/tr>\n
          (d)<\/td>\na
          \n factory;<\/td>\n<\/tr>\n
          (e)<\/td>\na
          \n workshop;<\/td>\n<\/tr>\n
          (f)<\/td>\n\n

          a mine, an oil or gas well, a quarry or
          \n any other
          \n place of extraction of natural resources.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

          \n<\/li>\n

        3. \n

          The term “permanent
          \n establishment”
          \n includes especially: \n <\/p>\n\n\n\n\n
          (a)<\/td>\n\n

          a building site, a construction,
          \n assembly or
          \n installation project or supervisory activities in connection therewith,
          \n but only where such site, project or activities continue for a period
          \n of more than six months; <\/p>\n<\/td>\n<\/tr>\n

          (b)<\/td>\n\n

          the furnishing of services, including
          \n consultancy
          \n services, by an enterprise through employees or other personnel engaged
          \n by the enterprise for such purpose, but only where activities of that
          \n nature continue (for the same or a connected project) within the
          \n country for a period or periods aggregating more than three months
          \n within any twelve-month period.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

          \n<\/li>\n

        4. \n

          Notwithstanding the preceding
          \n provision of this Article, the term “permanent establishment” shall be
          \n deemed not to include:\n <\/p>\n\n\n\n\n\n\n\n\n
          (a)<\/td>\n\n

          the use of facilities solely for the
          \n purpose of
          \n storage or display of goods or merchandise belonging to the enterprise;<\/p>\n<\/td>\n<\/tr>\n

          (b)<\/td>\n\n

          the maintenance of a stock of goods or
          \n merchandise
          \n belonging to the enterprise solely for the purpose of storage or
          \n display;<\/p>\n<\/td>\n<\/tr>\n

          (c)<\/td>\n\n

          the maintenance of a stock of goods or
          \n merchandise
          \n belonging to the enterprise solely for the purpose of processing by
          \n another enterprise;<\/p>\n<\/td>\n<\/tr>\n

          (d)<\/td>\n\n

          the maintenance of a fixed place of
          \n business solely
          \n for the purpose of purchasing goods or merchandise or for collecting
          \n information, for the enterprise; <\/p>\n<\/td>\n<\/tr>\n

          (e)<\/td>\n\n

          the maintenance of a fixed place of
          \n business solely
          \n for the purpose of advertising, for the supply of information, for
          \n scientific research or for similar activities which have a preparatory
          \n or auxiliary character, for the enterprise; <\/p>\n<\/td>\n<\/tr>\n

          (f)<\/td>\n\n

          the maintenance of a fixed place of
          \n business solely
          \n for any combination of activities mentioned in subparagraphs a) to e),
          \n provided that the overall activity of the fixed place of business
          \n resulting from this combination is of a preparatory or auxiliary
          \n character.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

          \n<\/li>\n

        5. \n

          Notwithstanding the provisions
          \n of
          \n paragraph 1 and 2, where a person – other than an agent of an
          \n independent status to whom paragraph 6 applies – is acting in a
          \n Contracting State on behalf of an enterprise of the other Contracting
          \n State, that enterprise shall be deemed to have a permanent
          \n establishment in the first-mentioned State in respect of any activities
          \n which that person undertakes for the enterprise, if such a
          \n person: \n <\/p>\n\n\n\n\n
          (a)<\/td>\n\n

          has and habitually exercises in that
          \n State an
          \n authority to conclude contracts in the name of the enterprise, unless
          \n the activities of such person are limited to those mentioned in
          \n paragraph 4 which, if exercised through a fixed place of business,
          \n would not make this fixed place of business a permanent establishment
          \n under the provision of that paragraph; or <\/p>\n<\/td>\n<\/tr>\n

          (b)<\/td>\n\n

          has no such authority, but habitually
          \n maintains in
          \n the first-mentioned State a stock of goods or merchandise from which he
          \n regularly delivers goods or merchandise on behalf of the
          \n enterprise. <\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

          \n<\/li>\n

        6. \n

          An enterprise of a Contracting
          \n State shall not be deemed to have a permanent establishment in the
          \n other Contracting State merely because it carries on business in that
          \n State through a broker, general commission agent or any other agent of
          \n an independent status, provided that such persons are acting in the
          \n ordinary course of their business. However, where the activities of
          \n such an agent are devoted wholly or almost wholly on behalf of that
          \n enterprise, he shall be considered an agent of dependent status and
          \n that enterprise shall be deemed to have a permanent establishment in
          \n that State.<\/p>\n<\/li>\n

        7. \n

          The fact that a company which is
          \n a
          \n resident of a Contracting State controls or is controlled by a company
          \n which is a resident of the other Contracting State, or which carries on
          \n business in that other State (whether through a permanent establishment
          \n or otherwise), shall not of itself constitute either company a
          \n permanent establishment of the other. <\/p>\n<\/li>\n<\/ol>\n

          Article 6
          \n INCOME FROM IMMOVABLE PROPERTY<\/b><\/p>\n

            \n
          1. \n

            Income derived by a resident of
            \n a
            \n country of a Contracting State from immovable property (including
            \n income from agriculture or forestry) situated in the other Contracting
            \n State may be taxed in that other State. <\/p>\n<\/li>\n

          2. \n

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

          3. \n

            The provisions of paragraph 1
            \n shall
            \n also apply to income derived from the direct use, letting, or use in
            \n any other form of immovable property. <\/p>\n<\/li>\n

          4. \n

            The provisions of paragraphs 1
            \n and
            \n 3 shall also apply to the income from immovable property of an
            \n enterprise and to income from immovable property used for the
            \n performance of independent personal services. <\/p>\n<\/li>\n<\/ol>\n

            Article 7
            \n BUSINESS PROFITS<\/b><\/p>\n

              \n
            1. \n

              The profits of an enterprise of
              \n one
              \n of a Contracting State shall be taxable only in that State unless the
              \n enterprise carries on business in the other Contracting State through a
              \n permanent establishment situated therein. If the enterprise carries on
              \n business as aforesaid, the profits of the enterprise may be taxed in
              \n the other State but only so much of them as is attributable to :\n <\/p>\n\n\n\n\n
              (a)<\/td>\n\n

              that permanent establishment; or<\/p>\n<\/td>\n<\/tr>\n

              (b)<\/td>\n\n

              sales within that other Contracting
              \n State of goods
              \n or merchandise of the same or similar kind as those being sold, or
              \n other business activities of the same or similar kind as those being
              \n carried on through that permanent establishment if the sale or the
              \n business activities had been made or carried on in that way with a view
              \n to avoiding taxes in that other State. <\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

              \n<\/li>\n

            2. \n

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

            3. \n

              In determining the profits of a
              \n permanent establishment, there shall be allowed as deductions expenses
              \n which are incurred for the purposes of the permanent establishment,
              \n including executive and general administrative expenses so incurred,
              \n whether in the State in which the permanent establishment is situated
              \n or elsewhere. <\/p>\n<\/li>\n

            4. \n

              Insofar as it has been customary
              \n in
              \n a Contracting State to determine the profits to be attributed to a
              \n permanent establishment on the basis of a certain percentage of the
              \n gross receipts of the enterprise or on the basis of an apportionment of
              \n the total profits of the enterprise to its various parts, nothing in
              \n paragraph 2 shall preclude that Contracting State from determining the
              \n profits to be taxed by such an apportionment as may be customary; the
              \n method of apportionment adopted shall, however, be such that the result
              \n shall be in accordance with the principles contained in this
              \n Article. <\/p>\n<\/li>\n

            5. \n

              No income or profits shall be
              \n attributed to a permanent establishment by reason of the mere purchase
              \n by that permanent establishment of goods or merchandise for the
              \n enterprise.<\/p>\n<\/li>\n

            6. \n

              For the purposes of the
              \n preceding
              \n paragraphs, the profits to be attributed to the permanent establishment
              \n shall be determined by the same method year by year unless there is
              \n good and sufficient reason to the contrary. <\/p>\n<\/li>\n

            7. \n

              Nothing in this Article shall
              \n affect any provisions of the law of either Contracting State at any
              \n time in force regarding the taxation of any income or profits from the
              \n business of any form of insurance. <\/p>\n<\/li>\n

            8. \n

              Where income or profits include
              \n items of income or profits which are dealt with separately in other
              \n Articles of this Agreement, then the provisions of those Articles shall
              \n not be affected by the provisions of this Article.<\/p>\n<\/li>\n<\/ol>\n

              Article 8
              \n SHIPPING AND AIR TRANSPORT<\/b><\/p>\n

                \n
              1. \n

                Profits of an enterprise of a
                \n Contracting State from the operation of ships or aircraft in
                \n international traffic shall be taxable only in that State.<\/p>\n<\/li>\n

              2. \n

                The provisions of paragraph 1
                \n shall
                \n also apply to profits derived from the participation in a pool, a joint
                \n business or an international operating agency but only to so much of
                \n the profits so derived as is attributable to the participant in
                \n proportion to its share in that joint operation.<\/p>\n<\/li>\n<\/ol>\n

                Article 9
                \n ASSOCIATED ENTERPRISE<\/b><\/p>\n

                Where :\n <\/p>\n\n\n\n\n
                (a)<\/td>\n\n

                an enterprise of a Contracting State
                \n participates
                \n directly or indirectly in the management, control or capital of an
                \n enterprise of the other Contracting State, or <\/p>\n<\/td>\n<\/tr>\n

                (b)<\/td>\n\n

                the same persons participate directly or
                \n indirectly in
                \n the management, control or capital of an enterprise of a Contracting
                \n State and an enterprise of the other Contracting State,<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                \n

                and
                \n in either case conditions are made or imposed between the two
                \n enterprises in their commercial or financial relations which differ
                \n from those which would be made between independent enterprises, then
                \n any profits which would, but for those conditions, have accrued to one
                \n of the enterprises, but, by reason of those conditions, have not so
                \n accrued, may be included in the profits of that enterprise and taxed
                \n accordingly.<\/div>\n

                Article 10
                \n DIVIDENDS<\/b><\/p>\n

                  \n
                1. \n

                  Dividends paid by a company
                  \n which
                  \n is a resident of a Contracting States to a resident of the other
                  \n Contracting State may be taxed in that other State.<\/p>\n<\/li>\n

                2. \n

                  However, such dividends may also
                  \n be
                  \n taxed in the Contracting State of which the company paying the
                  \n dividends is a resident and according to the laws of that State, but if
                  \n the recipient is the beneficial owner of the dividends the tax so
                  \n charged shall not exceed 15 per cent of the gross amount of the
                  \n dividends. The competent authorities of the Contracting States shall by
                  \n mutual agreement settle the mode of application of this limitation.
                  \n This paragraph shall not affect the taxation of the company in respect
                  \n of the profits out of which the dividends are paid.<\/p>\n<\/li>\n

                3. \n

                  The term “dividends” as used in
                  \n this Article means income from shares and other income assimilated to
                  \n income from shares by the taxation law of the Contracting State of
                  \n which the company making the distribution is a resident. <\/p>\n<\/li>\n

                4. \n

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

                5. \n

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

                  Article 11
                  \n INTEREST<\/b><\/p>\n

                    \n
                  1. \n

                    Interest arising in a
                    \n Contracting
                    \n State and paid to a resident of the other Contracting State may be
                    \n taxed in that other State. <\/p>\n<\/li>\n

                  2. \n

                    However, such interest may also
                    \n be
                    \n taxed in the Contracting State in which it arises and according to the
                    \n laws of that State, but if the recipient is the beneficial owner of the
                    \n interest the tax so charged shall not exceed 10 per cent of the gross
                    \n amount of the interest. The competent authorities of the Contracting
                    \n States shall by mutual agreement settle the mode of application of this
                    \n limitation. <\/p>\n<\/li>\n

                  3. \n

                    Notwithstanding the provisions
                    \n of
                    \n paragraph 2, interest arising in a Contracting State and received by
                    \n the Government of the other Contracting State including a political
                    \n subdivision or a local authority thereof or the central bank of that
                    \n other Contracting State shall be taxable only in that other Contracting
                    \n State. <\/p>\n<\/li>\n

                  4. \n

                    The term “interest” as used in
                    \n this
                    \n Article means income from debt-claims of every kind, whether or not
                    \n secured by mortgage and whether or not carrying a right to participate
                    \n in the debtor’s profits, and in particular, income from Government
                    \n securities and income from bonds or debentures, including premiums and
                    \n prizes attaching to such securities, bonds or debentures. However, this
                    \n term does not include income dealt with in Article 10. Penalty charges
                    \n for late payment shall not be regarded as interest for the purpose of
                    \n this Article. <\/p>\n<\/li>\n

                  5. \n

                    The provisions of paragraphs 1
                    \n and
                    \n 2 shall not apply if the beneficial owner of the interest, being a
                    \n resident of a Contracting State, carries on business in other
                    \n Contracting State in which the interest arises, through a permanent
                    \n establishment situated therein, or performs in that other State
                    \n independent personal services from a fixed base situated therein, and
                    \n the debt-claim in respect of which the interest is paid is effectively
                    \n connected with such permanent establishment or fixed base. In such
                    \n case, the provisions of Article 7 or Article 14, as the case may be,
                    \n shall apply. <\/p>\n<\/li>\n

                  6. \n

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

                  7. \n

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

                    Article 12
                    \n ROYALTIES<\/b><\/p>\n

                      \n
                    1. \n

                      Royalties arising in a
                      \n Contracting
                      \n State and paid to a resident of the other Contracting State may
                      \n be taxed in that other
                      \n State. <\/p>\n<\/li>\n

                    2. \n

                      However, such royalties may also
                      \n be
                      \n taxed in the Contracting State in which they arise, and according to
                      \n the laws of that Contracting State, but if the recipient is the
                      \n beneficial owner of the royalties the tax so charged shall not exceed
                      \n 15 per cent of the gross amount of the royalties. The competent
                      \n authorities of the Contracting States shall by mutual agreement settle
                      \n the mode of application of this limitation. <\/p>\n<\/li>\n

                    3. \n

                      The term “royalties” as used in
                      \n this Article means payments of any kind received as a consideration for
                      \n the use of, or the right to use, any copyright of literary, artistic or
                      \n scientific work including cinematograph films, films or videotapes for
                      \n use in connection with television or tapes for use in connection with
                      \n radio broadcasting, any patent, trade mark, design or model, plan,
                      \n secret formula or process, or for the use of, or the right to use,
                      \n industrial, commercial or scientific equipment, or for information
                      \n concerning industrial, commercial or scientific experience. <\/p>\n<\/li>\n

                    4. \n

                      The provisions of paragraphs 1
                      \n and
                      \n 2 shall not apply if the beneficial owner of the royalties, being a
                      \n resident of a Contracting State, carries on business in the other
                      \n Contracting State in which the royalties arise, through a permanent
                      \n establishment situated therein, or performs in that other State
                      \n independent personal services from a fixed base situated therein, and
                      \n the right or property in respect of which the royalties are paid is
                      \n effectively connected with such permanent establishment or fixed base.
                      \n In such case, the provisions of Article 7 or Article 14, as the case
                      \n may be, shall apply. <\/p>\n<\/li>\n

                    5. \n

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

                    6. \n

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

                      Article 13
                      \n ALIENATION OF PROPERTY<\/b><\/p>\n

                        \n
                      1. \n

                        Income or gains derived by a
                        \n resident of a Contracting State from the alienation of immovable
                        \n property referred to in Article 6 and situated in the other Contracting
                        \n State may be taxed in that other State. <\/p>\n<\/li>\n

                      2. \n

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

                      3. \n

                        Income or gains of an enterprise
                        \n of
                        \n a Contracting State from the alienation of ships or aircraft operated
                        \n in international traffic or movable property pertaining to the
                        \n operation of such ships or aircraft, shall be taxable only in that
                        \n State. <\/p>\n<\/li>\n

                      4. \n

                        Income or gains from the
                        \n alienation
                        \n of any property other than that referred to in paragraphs 1, 2 and 3,
                        \n shall be taxable only in the Contracting State of which the alienator
                        \n is a resident.<\/p>\n<\/li>\n<\/ol>\n

                        Article 14
                        \n INDEPENDENT PERSONAL SERVICES<\/b><\/p>\n

                          \n
                        1. \n

                          Income derived by a resident of
                          \n a
                          \n Contracting State in respect of professional services or other
                          \n activities of an independent character shall be taxable only in that
                          \n State unless such services are performed in the other Contracting State
                          \n and :\n <\/p>\n\n\n\n\n\n
                          (a)<\/td>\n\n

                          the individual is present in the other
                          \n State for a
                          \n period or periods exceeding in the aggregate 90 days in any consecutive
                          \n twelve month period, or <\/p>\n<\/td>\n<\/tr>\n

                          (b)<\/td>\n\n

                          the individual has a fixed base
                          \n regularly available
                          \n to him in the other State for the purpose of performing his activities.<\/p>\n<\/td>\n<\/tr>\n

                          \n

                          In such case, the income may be taxed in
                          \n that other
                          \n State but only so much of it as is attributable to activities connected
                          \n with that fixed base or performed during such period or periods.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                          \n<\/li>\n

                        2. \n

                          The term “professional services”
                          \n includes, especially, independent scientific, literary, artistic,
                          \n educational or teaching activities as well as the independent
                          \n activities of physicians, lawyers, engineers, architects, dentists and
                          \n accountants. <\/p>\n<\/li>\n<\/ol>\n

                          Article 15
                          \n DEPENDENT PERSONAL SERVICES<\/b><\/p>\n

                            \n
                          1. \n

                            Subject to the provisions of
                            \n Articles 16, 18, 19, 20 and 21, salaries, wages and other similar
                            \n remuneration derived by a resident of a Contracting State in respect of
                            \n an employment shall be taxable only in that State unless the employment
                            \n is exercised in the other Contracting State. If the employment is so
                            \n exercised, such remuneration as is derived therefrom may be taxed in
                            \n that other State. <\/p>\n<\/li>\n

                          2. \n

                            Notwithstanding the provisions
                            \n of
                            \n paragraph 1, remuneration derived by a resident of a Contracting State
                            \n in respect of an employment exercised in the other Contracting State
                            \n shall be taxable only in the first-mentioned State if:\n <\/p>\n\n\n\n\n\n
                            (a)<\/td>\n\n

                            the recipient is present in the other
                            \n State for a
                            \n period or periods not exceeding in the aggregate 183 days in any
                            \n consecutive twelve month period, and <\/p>\n<\/td>\n<\/tr>\n

                            (b)<\/td>\n\n

                            the remuneration is paid by, or on
                            \n behalf of, an
                            \n employer who is not a resident of the other Contracting State, and<\/p>\n<\/td>\n<\/tr>\n

                            (c)<\/td>\n\n

                            the remuneration is not borne by a
                            \n permanent
                            \n establishment or a fixed base which the employer has in the other State.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                            \n<\/li>\n

                          3. \n

                            Notwithstanding the preceding
                            \n provisions of this Article, remuneration derived in respect of an
                            \n employment exercised aboard a ship or aircraft operated in
                            \n international traffic by an enterprise of a Contracting State may be
                            \n taxed in that Contracting State. <\/p>\n<\/li>\n<\/ol>\n

                            Article 16
                            \n DIRECTORS’ FEES<\/b><\/p>\n

                            Directors’
                            \n fees and other similar payments derived by a resident of a Contracting
                            \n State in his capacity as a member of the board of directors of a
                            \n company which is a resident of the other Contracting State may
                            \n be taxed in that other State.<\/div>\n

                            Article 17
                            \n ARTISTES AND ATHLETES<\/b><\/p>\n

                              \n
                            1. \n

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

                            2. \n

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

                            3. \n

                              Notwithstanding the provisions
                              \n of
                              \n paragraphs 1 and 2, income derived from activities referred to in
                              \n paragraph 1 performed under a cultural agreement or arrangement between
                              \n the Contracting States shall be exempt from tax in the Contracting
                              \n State in which the activities are exercised if the visit to that State
                              \n is wholly or substantially supported by funds of the government of the
                              \n other Contracting State, a local authority or public institution
                              \n thereof. <\/p>\n<\/li>\n<\/ol>\n

                              Article 18
                              \n PENSION AND ANNUITIES<\/b><\/p>\n\n\n\n\n\n\n
                              \n 1.<\/td>\n\n

                              Subject to the provisions of paragraph 2 of
                              \n Article 19,
                              \n pensions, annuities and other similar remuneration paid to a resident
                              \n of the other Contracting State in consideration of past employment
                              \n shall be taxable only in that State.<\/p>\n<\/td>\n<\/tr>\n

                              \n 2.<\/td>\n\n

                              Notwithstanding the provisions of paragraph
                              \n 1, pensions
                              \n and other payments made under the social security legislation of a
                              \n Contracting State may be taxed in that State. <\/p>\n<\/td>\n<\/tr>\n

                              3.<\/td>\n\n (a)<\/td>\n\n

                              The term “pensions” as used in this Article
                              \n means
                              \n periodic payments made in consideration for past services rendered.<\/p>\n<\/td>\n<\/tr>\n

                              \n (b)<\/td>\n\n

                              The term “annuities” as used in this Article
                              \n means a
                              \n stated sum payable periodically at stated times during life or during a
                              \n specified or ascertainable period of time under an obligation to make
                              \n the payments in return for adequate and full consideration in money or
                              \n money’s worth.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                              Article 19
                              \n GOVERNMENT SERVICE<\/b><\/p>\n\n\n\n\n\n\n\n\n\n
                              1.<\/td>\n\n (a)<\/td>\n\n

                              Remuneration, other than a pensions, paid by
                              \n a
                              \n Contracting State, or a statutory body or a local authority thereof, to
                              \n an individual in respect of services rendered to that State or
                              \n subdivision or authority shall be taxable only in that State.<\/p>\n<\/td>\n<\/tr>\n

                              (b)<\/td>\n\n

                              However, such remuneration shall be taxable
                              \n only in the
                              \n other Contracting State if the services are rendered in that State and
                              \n the individual is a resident of that State who: <\/p>\n<\/td>\n<\/tr>\n

                              \n (i)<\/td>\n\n

                              is a national of that State; or<\/p>\n<\/td>\n<\/tr>\n

                              \n (ii)<\/td>\n\n

                              did not become a resident of that State
                              \n solely for the
                              \n purpose of rendering the services.<\/p>\n<\/td>\n<\/tr>\n

                              2.<\/td>\n\n (a)<\/td>\n\n

                              Any pension paid by, or out of funds created
                              \n by, a
                              \n Contracting State or a political subdivision a local authority thereof
                              \n to an individual in respect to services rendered to that State or
                              \n subdivision or authority shall be taxable only in that State. <\/p>\n<\/td>\n<\/tr>\n

                              \n (b)<\/td>\n\n

                              However, such pension shall be taxable only
                              \n in the other
                              \n Contracting State if the individual is a resident of, and a national
                              \n of, that State. <\/p>\n<\/td>\n<\/tr>\n

                              \n 3.<\/td>\n\n

                              The provisions of Articles 15, 16 and 18
                              \n shall apply to
                              \n remuneration and pensions in respect of services rendered in connection
                              \n with a business carried on by a Contracting State or a political
                              \n subdivision or a local authority thereof. <\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                              Article 20
                              \n PROFESSORS AND TEACHERS<\/b><\/p>\n

                                \n
                              1. \n

                                A professor or teacher who is or
                                \n was a resident of a Contracting State immediately before making a visit
                                \n to the other Contracting State, and who, at the invitation of any
                                \n university, college, school, or other similar educational institution,
                                \n which is recognized by the competent authority in that other
                                \n Contracting State, visits that other Contracting State for a period not
                                \n exceeding two years solely for the purpose of teaching or research or
                                \n both at such educational institution shall be exempt from tax in that
                                \n other Contracting State on any remuneration for such teaching or
                                \n research. However, to the extent the above-mentioned remuneration is
                                \n not taxed in the State where the recipient is a resident, the
                                \n remuneration may be taxed in the other state. <\/p>\n<\/li>\n

                              2. \n

                                This Article shall not apply to
                                \n remuneration which a professor or teacher receives for conducting
                                \n research if such research is undertaken primarily for the private
                                \n benefit of a specific person or persons. <\/p>\n<\/li>\n<\/ol>\n

                                Article 21
                                \n STUDENTS<\/b><\/p>\n

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

                                Article 22
                                \n OTHER INCOME<\/b><\/p>\n

                                Items
                                \n of income of a resident of a Contracting State not dealt with in the
                                \n foregoing Articles of this Agreement shall be taxable only in that
                                \n State except that, if such income is derived from sources within the
                                \n other Contracting State, it may also be taxed in that other State.<\/div>\n

                                Article 23
                                \n METHODS OF ELIMINATION OF DOUBLE TAXATION<\/b><\/p>\n

                                  \n
                                1. \n

                                  In the case of Indonesia, double
                                  \n taxation shall be avoided as follows: \n <\/p>\n\n\n\n\n
                                  (a)<\/td>\n\n

                                  Indonesia, when imposing tax on resident
                                  \n of
                                  \n Indonesia, may include in the basis upon which such tax is imposed the
                                  \n items of income which may be taxed in New Zealand in accordance with
                                  \n the provisions of this Agreement;<\/p>\n<\/td>\n<\/tr>\n

                                  (b)<\/td>\n\n

                                  Where a resident of Indonesia derives
                                  \n income from
                                  \n New Zealand and that income may be taxed in New Zealand in accordance
                                  \n with the provisions of this Agreement, the amount of New Zealand tax
                                  \n payable in respect of that income shall be allowed as a credit against
                                  \n the Indonesian tax imposed on that resident. The amount of credit,
                                  \n however, shall not exceed that part of the Indonesian tax which is
                                  \n appropriate to that income.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                  \n<\/li>\n

                                2. \n

                                  In the case of New Zealand,
                                  \n double
                                  \n taxation shall be avoided as follows: 
                                  \n Subject to any provisions of the law of New Zealand which may from time
                                  \n to time be in force and which relate to the allowance of a credit
                                  \n against New Zealand tax of tax paid in a country outside New Zealand
                                  \n (which shall not affect the general principle hereof), Indonesian tax
                                  \n paid under the law of Indonesia and consistently with this Agreement,
                                  \n whether directly or by deduction, in respect of income derived by a New
                                  \n Zealand resident from sources in Indonesia (excluding, in the case of a
                                  \n dividend, tax paid in respect of the profits out of which the dividend
                                  \n is paid) shall be allowed as a credit against New Zealand tax payable
                                  \n in respect of that income.<\/p>\n<\/li>\n

                                3. \n

                                  For the purposes of this
                                  \n Article,
                                  \n profits, income or gains of a resident of a Contracting State which are
                                  \n taxed in the other Contracting State in accordance with this Agreement
                                  \n shall be deemed to arise from sources in that other State. <\/p>\n<\/li>\n<\/ol>\n

                                  Article 24
                                  \n MUTUAL AGREEMENT PROCEDURE<\/b><\/p>\n

                                    \n
                                  1. \n

                                    Where a resident of a
                                    \n Contracting
                                    \n State considers that the actions of one or both of the Contracting
                                    \n States result or will result for him in taxation not in accordance with
                                    \n the provisions of this Agreement, he may, irrespective of the remedies
                                    \n provided by the domestic law of those States, present his case to the
                                    \n competent authority of the Contracting State of which he is a resident.
                                    \n This case must be presented within two years from the first
                                    \n notification of the action giving rise to taxation not in accordance
                                    \n with the provisions of the Agreement. <\/p>\n<\/li>\n

                                  2. \n

                                    The competent authority shall
                                    \n endeavor, if the objection appears to it to be justified and if it is
                                    \n not itself able to arrive at a satisfactory solution, to resolve the
                                    \n case by mutual agreement with the competent authority of the other
                                    \n Contracting State, with a view to the avoidance of taxation which is
                                    \n not in accordance with the Agreement. <\/p>\n<\/li>\n

                                  3. \n

                                    The competent authorities of
                                    \n the
                                    \n Contracting States shall endeavor to resolve by mutual agreement any
                                    \n difficulties or doubts arising as to the interpretation or application
                                    \n of the Agreement. They may also consult together for the elimination of
                                    \n double taxation in cases not provided for in the Agreement.<\/p>\n<\/li>\n

                                  4. \n

                                    The competent authorities of the
                                    \n Contracting States may communicate with each other directly for the
                                    \n purpose of giving effect to the provisions of the Agreement.<\/p>\n<\/li>\n<\/ol>\n

                                    Article 25
                                    \n EXCHANGE OF INFORMATION<\/b><\/p>\n

                                      \n
                                    1. \n

                                      The competent authorities of the
                                      \n Contracting States shall exchange such information as is necessary for
                                      \n carrying out the provisions of this Agreement or of the domestic laws
                                      \n of the Contracting State concerning taxes covered by the Agreement
                                      \n insofar as the taxation thereunder is not contrary to the Agreement.
                                      \n The exchange of information is not restricted by Article 1. Any
                                      \n information received by a Contracting State shall be treated as secret
                                      \n in the same manner as information obtained under the domestic laws of
                                      \n that State and shall be disclosed only to persons or authorities
                                      \n (including courts and administrative bodies) involved in the assessment
                                      \n or collection of, the enforcement or prosecution in respect of, or the
                                      \n determination of appeals in relation to, the taxes covered by the
                                      \n Agreement. Such persons or authorities shall use the information only
                                      \n for such purposes. They may disclose the information in public court
                                      \n proceedings or in judicial decisions. <\/p>\n<\/li>\n

                                    2. \n

                                      In no case shall the provisions
                                      \n of
                                      \n paragraph 1 be construed so as to impose on a Contracting State the
                                      \n obligation: <\/p>\n\n\n\n\n\n
                                      (a)<\/td>\n\n

                                      to carry out administrative measures at
                                      \n variance
                                      \n with the laws and administrative practice of that or of the other
                                      \n Contracting State;<\/p>\n<\/td>\n<\/tr>\n

                                      (b)<\/td>\n\n

                                      to supply information which is not
                                      \n obtainable under
                                      \n the laws or in the normal course of the administration of that or of
                                      \n the other Contracting State;<\/p>\n<\/td>\n<\/tr>\n

                                      (c)<\/td>\n\n

                                      to supply information which would
                                      \n disclose any
                                      \n trade, business, industrial, commercial or professional secret or trade
                                      \n process, or information, the disclosure of which would be contrary to
                                      \n public policy.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                      \n<\/li>\n<\/ol>\n

                                      Article 26
                                      \n DIPLOMATIC AND CONSULAR OFFICERS<\/b><\/p>\n

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

                                      Article 27
                                      \n ENTRY INTO FORCE<\/b><\/p>\n

                                        \n
                                      1. \n

                                        This Agreement shall be ratified
                                        \n and the instrument of ratification shall be exchange at Wellington as
                                        \n soon as possible. <\/p>\n<\/li>\n

                                      2. \n

                                        This Agreement shall enter into
                                        \n force after the expiration of thirty days from the date of the exchange
                                        \n of instruments of ratification and shall have effect: \n <\/p>\n\n\n\n\n
                                        (a)<\/td>\n\n

                                        in Indonesia :
                                        \n in respect of income derived during any taxable year beginning on or
                                        \n after the first day of January in the calendar year next following that
                                        \n in which this Agreement enters into force;<\/p>\n<\/td>\n<\/tr>\n

                                        (b)<\/td>\n\n

                                        in New Zealand :
                                        \n in respect of income derived during any income year beginning on or
                                        \n after 1 April in the calendar year next following that in which the
                                        \n notice of termination is given.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                        \n<\/li>\n<\/ol>\n

                                        Article 28
                                        \n TERMINATION<\/b><\/p>\n

                                        \n
                                        This Agreement shall
                                        \n continue in effect indefinitely but either Contracting State may, on or
                                        \n before June 30 in any calendar year after the fourth year following the
                                        \n exchange of the instruments of ratification, give notice of termination
                                        \n to the other Contracting State and in such event the Agreement shall
                                        \n cease to have effect:\n <\/div>\n<\/p><\/div>\n\n\n\n\n
                                        (a)<\/td>\n\n

                                        in Indonesia :
                                        \n in respect of income derived during any taxable year beginning on or
                                        \n after the first day of January in the calendar year next following that
                                        \n in which the notice of termination is given.<\/p>\n<\/td>\n<\/tr>\n

                                        (b)<\/td>\n\n

                                        in New Zealand :
                                        \n in respect of income derived during any income year beginning on or
                                        \n after 1 April in the calendar year next following that in which the
                                        \n notice of termination is given.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                        \n

                                        IN
                                        \n WITNESS WHEREOF the undersigned, duly authorized thereto, have signed
                                        \n the present Agreement.<\/div>\n
                                        <\/div>\n
                                        \n
                                         <\/div>\n

                                        DONE in duplicate at Wellington this 25th day of March 1987 in the
                                        \n English language.\n <\/p><\/div>\n\n\n\n
                                        \n

                                        For the Government of
                                        \n the Republik of Indonesia<\/p>\n<\/td>\n

                                        		\n

                                        For the Government of
                                        \n New Zealand<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                        \n

                                        \n

                                        PROTOCOL<\/b><\/p>\n

                                        THE
                                        \n REPUBLIC OF INDONESIA and NEW ZEALAND have agreed at the signing of the
                                        \n Agreement between the two States for the Avoidance of Double Taxation
                                        \n and the Prevention of Fiscal Evasion with Respect to Taxes on Income
                                        \n upon the following provision which shall form an integral part of the
                                        \n said Agreement.\n <\/div>\n

                                        With
                                        \n reference to Article 5,<\/p>\n\n\n\n\n
                                        (a)<\/td>\n\n

                                        notwithstanding the provisions of paragraph
                                        \n 3 an
                                        \n enterprise shall be deemed to have a permanent establishment in a
                                        \n Contracting State and to carry on business through that permanent
                                        \n establishment if it carries on activities in that State in connection
                                        \n with the exploration or exploitation of natural resources situated in
                                        \n that State; <\/p>\n<\/td>\n<\/tr>\n

                                        (b)<\/td>\n\n

                                        the provisions of paragraph (a) of this
                                        \n Protocol shall
                                        \n not apply if such activities are carried on for a period not exceeding
                                        \n three months in the aggregate in any consecutive twelve month period.
                                        \n However for the purposes of this paragraph activities carried on in
                                        \n that State by an enterprise associated with another enterprise shall be
                                        \n regarded as carried on by the enterprise with which it is associated if
                                        \n those activities are connected with activities carried on in that State
                                        \n by the last-mentioned enterprise. An enterprise shall be deemed to be
                                        \n associated with another enterprise if one is controlled directly or
                                        \n indirectly by the other, or if both are controlled directly or
                                        \n indirectly by a third person or persons. <\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                        <\/p>\n

                                        IN
                                        \n WITNESS WHEREOF the undersigned have signed this Protocol which shall
                                        \n have the same force and validity as if it were inserted word by word in
                                        \n the Agreement.<\/div>\n
                                         <\/div>\n
                                        \n
                                        DONE in duplicate at
                                        \n Wellington this 25th day of March 1987 in the English Language.\n <\/div>\n

                                        \n <\/div>\n\n\n\n
                                        \n

                                        For the Government of
                                        \n the Republik of Indonesia<\/p>\n<\/td>\n

                                        		\n

                                        For the Government of
                                        \n New Zealand<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table><\/div>\n<\/p><\/div>\n","protected":false},"excerpt":{"rendered":"

                                        AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND THE GOVERNMENT OF NEW ZEALAND 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 Contracting States. 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