{"id":487,"date":"2025-10-01T03:30:12","date_gmt":"2025-10-01T03:30:12","guid":{"rendered":"https:\/\/whimsical-pyramid.localsite.io\/?p=487"},"modified":"2025-10-01T03:30:12","modified_gmt":"2025-10-01T03:30:12","slug":"tunisia","status":"publish","type":"post","link":"https:\/\/investinasia.id\/education\/tax-treaty\/tunisia\/","title":{"rendered":"Tunisia"},"content":{"rendered":"
\n
\n

AGREEMENT
\n BETWEEN
\n THE REPUBLIC OF INDONESIA
\n AND
\n THE REPUBLIC OF TUNISIA<\/p>\n

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

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

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

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

    \n
  1. \n

    This Agreement shall apply to
    \n taxes
    \n on income imposed on behalf of a
    \n Contracting State, irrespective of the manner in which they are levied.
    \n  <\/p>\n<\/li>\n

  2. \n

    There shall be regarded as taxes
    \n on
    \n income all taxes imposed on total income or on elements of income,
    \n including taxes on gains from the alienation of movable or immovable
    \n property.<\/p>\n<\/li>\n

  3. \n

    The existing taxes to which the
    \n Agreement shall apply are :\n <\/p>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
    (a)<\/td>\nin
    \n the case of Indonesia,
    \n the
    \n income tax imposed under the Undang-undang Pajak Penghasilan 1984 (Law
    \n No. 7 of 1983)
    \n (hereinafter referred to
    \n as “Indonesian tax”);\n <\/td>\n<\/tr>\n
    (b)<\/td>\nin
    \n the case of Tunisia :<\/td>\n<\/tr>\n
    (i)<\/td>\nthe
    \n tax on
    \n business income (l’imp\u00f4t sur les
    \n b\u00e9n\u00e9fices industriels et commerciaux);<\/td>\n<\/tr>\n
    (ii)<\/td>\nthe
    \n corporation tax (l’imp\u00f4t sur les
    \n b\u00e9n\u00e9fices des soci\u00e9t\u00e9s);<\/td>\n<\/tr>\n
    (iii)<\/td>\nthe
    \n tax on
    \n income from non-commercial occupations (l’imp\u00f4t sur les
    \n b\u00e9n\u00e9fices des professions non- commerciales);<\/td>\n<\/tr>\n
    (iv)<\/td>\nthe
    \n tax on
    \n wages and salaries (l’imp\u00f4t sur les traitements et salaires);<\/td>\n<\/tr>\n
    (v)<\/td>\nthe
    \n agricultural tax (l’imp\u00f4t agricole);<\/td>\n<\/tr>\n
    (vi)<\/td>\nthe
    \n tax on
    \n capital appreciation of immovable properties ( l impt sur les
    \n plus-values immobilires);<\/td>\n<\/tr>\n
    (vii)<\/td>\nthe
    \n tax on
    \n income from debts, deposits, guarantees and current accounts
    \n (l’imp\u00f4t sur le revenu des cr\u00e9ances,
    \n d\u00e9p\u00f4ts, cautionnements et comptes courants) (IRC);<\/td>\n<\/tr>\n
    (viii)<\/td>\nthe
    \n exceptional tax for solidarity (la contribution exceptionnelle de
    \n solidarit\u00e9);<\/td>\n<\/tr>\n
    (ix)<\/td>\nthe
    \n tax on
    \n income from transferable securities (l’imp\u00f4t sur le revenu
    \n des valeurs mobili\u00e8res);<\/td>\n<\/tr>\n
    (x)<\/td>\nthe
    \n State personal levy (la contribution personelle d’Etat)\n <\/td>\n<\/tr>\n
    (hereinafter
    \n referred to as “Tunisian tax”).<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

    \n<\/li>\n

  4. \n

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

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

      \n
    1. \n

      For the purposes of this
      \n Agreement, unless the context otherwise requires :\n <\/p>\n\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 “Indonesia”
      \n comprises the territory of the Republic of Indonesia as defined in its
      \n laws and the adjacent areas over which the Republic of Indonesia has
      \n sovereign rights or jurisdiction in accordance with international law;<\/p>\n<\/td>\n<\/tr>\n

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

      the term “Tunisia” used in a
      \n geographical sense, means the territory of the Tunisian Republic,
      \n including any area lying beyond the territorial waters of Tunisia
      \n which, under the law of Tunisia and in accordance with international
      \n law, is an area within which Tunisia may exercise rights in respect of
      \n the sea bed and its sub-soil and their natural resources;<\/p>\n<\/td>\n<\/tr>\n

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

      the terms “a Contracting
      \n State” and “the other Contracting State” mean Tunisia or Indonesia, as
      \n the context requires;<\/p>\n<\/td>\n<\/tr>\n

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

      the term “tax” means
      \n Indonesian tax or Tunisian tax, as the context requires;<\/p>\n<\/td>\n<\/tr>\n

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

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

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

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

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

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

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

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

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

      all individuals possessing
      \n the nationality of a Contracting State;<\/p>\n<\/td>\n<\/tr>\n

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

      all legal persons,
      \n partnership and associations deriving their status as such from the
      \n laws in force in a Contracting State;<\/p>\n<\/td>\n<\/tr>\n

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

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

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

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

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

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

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

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

      \n<\/li>\n

    2. \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 law of that State concerning the taxes to which the Agreement
      \n applies.<\/p>\n<\/li>\n<\/ol>\n

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

        \n
      1. \n

        For the purpose of this
        \n Agreement,
        \n the term “resident of a Contracting State” means any person who, under
        \n the laws of that State, is liable to tax therein by reason of his
        \n domicile, residence, place of head office, place of management or any
        \n other criterion of a similar nature. But this term does not include any
        \n person who is liable to tax in that State in respect only of income
        \n from sources in that State.<\/p>\n<\/li>\n

      2. \n

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

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

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

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

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

        iif he has an habitual abode
        \n in both States or in neither of them, he shall be deemed to be a
        \n resident of the State of which he is a national;<\/p>\n<\/td>\n<\/tr>\n

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

        if he is a national of both
        \n States or of neither of them, the competent authorities of the
        \n Contracting States shall 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, then it shall be deemed to be a resident of the
        \n State in which its place of effective management is situated. In case
        \n of doubt the competent authorities of the Contracting States shall
        \n settle the question by mutual agreement.<\/p>\n<\/li>\n<\/ol>\n

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

          \n
        1. \n

          For the purposes 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
          \n 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;
          \n and<\/td>\n<\/tr>\n
          (f)<\/td>\n\n

          a mine, a quarry or any
          \n other 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 likewise encompasses:\n <\/p>\n\n\n\n\n
          (a)<\/td>\n\n

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

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

          the furnishing of services,
          \n including consultancy services, by an enterprise for such purpose, but
          \n only where activities of that nature continue (for the same or a
          \n connected project) within the country for a period or periods
          \n aggregating more than three months within any 12-month period.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

          \n<\/li>\n

        4. \n

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

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

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

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

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

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

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

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

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

          the maintenance of a fixed
          \n place of business solely for the purpose of carrying on, for the
          \n enterprise, any other activity of a preparatory or auxiliary character;<\/p>\n<\/td>\n<\/tr>\n

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

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

          \n<\/li>\n

        5. \n

          Notwithstanding the provisions
          \n of
          \n paragraphs 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 Contracting State in respect of
          \n any activities which that person undertakes for the enterprise, if such
          \n a person:\n <\/p>\n\n\n\n\n
          (a)<\/td>\n\n

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

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

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

          \n<\/li>\n

        6. \n

          An enterprise shall not be
          \n deemed
          \n to have a permanent establishment in a Contracting State merely because
          \n it carries on business in that other State through a broker, general
          \n commission agent or any other agent of an independent status, provided
          \n that such persons are acting in the ordinary course of their business.<\/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

        8. \n

          An insurance enterprise of a
          \n Contracting State shall, except in regard to re-insurance, be deemed to
          \n have a permanent establishment in the other State, if it collects
          \n premiums in the territory of that State or insures risks situated
          \n therein through an employee or through a representative who is not an
          \n agent of an independent status within the meaning of paragraph 6.<\/p>\n<\/li>\n<\/ol>\n

          ARTICLE
          \n 6
          \n INCOME FROM IMMOVABLE PROPERTY<\/p>\n

            \n
          1. \n

            Income derived by a resident of
            \n a
            \n Contracting State from immovable property (including income from
            \n agriculture or forestry) situated in the other Contracting State may be
            \n 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 a 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 consideration for the working of, or the right 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 sue 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
            \n 7
            \n BUSINESS PROFITS<\/p>\n

              \n
            1. \n

              The profits of an enterprise of
              \n a
              \n 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
              \n establishment; or<\/p>\n<\/td>\n<\/tr>\n

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

              sales of goods or merchandise
              \n of the same or similar kind as those sold, or other business activities
              \n of the same or similar kind as those effected through that permanent
              \n establishment.<\/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 business of the permanent
              \n establishment including executive and general administrative expenses
              \n so incurred, whether in the State in which the permanent establishment
              \n is situated or elsewhere.  <\/p>\n

              However, no such deduction shall be allowed in respect of amounts, if
              \n any, paid (otherwise than towards reimbursement of actual expenses) by
              \n the permanent establishment to the head office of the enterprise or any
              \n of its other offices, by way of royalties, fees or other similar
              \n payments in return for the use of patents or other rights, or by way of
              \n commission, for specific services performed or for management, or,
              \n except in the case of a banking enterprise, by way of interest on
              \n moneys lent to the permanent establishment. Likewise, no account shall
              \n be taken, in the determination of the profits of a permanent
              \n establishment, for amounts charged (otherwise than towards
              \n reimbursement of actual expenses), by the permanent establishment to
              \n the head office of the enterprise or any of its other offices, by way
              \n of royalties, fees or other similar payments in return for the use of
              \n patents or other rights, or by way of commission for specific services
              \n performed or for management, or, except in the case of a banking
              \n enterprise by way of interest on moneys lent to the head office of the
              \n enterprise or any of its other offices.<\/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 an apportionment of the total
              \n profits of the enterprise to its various parts, nothing in paragraph 2
              \n shall preclude a Contracting State from determining the profits to be
              \n taxed by such an apportionment as may be customary; the method of
              \n apportionment adopted shall, however, be such that the result shall be
              \n in accordance with the principles contained in this Article.<\/p>\n<\/li>\n

            5. \n

              For the purpose of the 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

            6. \n

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

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

                \n
              1. \n

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

              2. \n

                The profits derived from the
                \n operation of ships or aircraft within places in a Contracting State
                \n shall be taxable only in that State.<\/p>\n<\/li>\n

              3. \n

                The provision 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.<\/p>\n<\/li>\n<\/ol>\n

                Article
                \n 9
                \n ASSOCIATED ENTERPRISES<\/p>\n

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

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

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

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

                \n

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

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

                  \n
                1. \n

                  Dividends paid by a company
                  \n which
                  \n is a resident of a Contracting State 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 12% of the gross amount of the dividends. This
                  \n paragraph shall not affect the taxation of the company in respect of
                  \n 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 or other rights, not being
                  \n debt-claims, participating in profits, as well as income from other
                  \n corporate rights which is subjected to the same taxation treatment as
                  \n income from shares by the laws of the State of which the company making
                  \n 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 the
                  \n company’s undistributed profits, even if the dividend paid or the
                  \n undistributed profits consist wholly or partly of profits or income
                  \n arising in such other State.<\/p>\n<\/li>\n

                6. \n

                  Notwithstanding any other
                  \n provisions of this Agreement where a company which is a resident of a
                  \n Contracting State has a permanent establishment in the other
                  \n Contracting State, the profits of the permanent establishment may be
                  \n subjected to an additional tax in that other State in accordance with
                  \n its law, but the additional tax so charged shall not exceed 12% of the
                  \n amount of such profits after deducting therefrom income tax and other
                  \n taxes on income imposed thereon in that other State.<\/p>\n<\/li>\n

                7. \n

                  The provisions of paragraph 6 of
                  \n this Article shall not affect the provisions contained in any
                  \n production sharing contracts and contracts of work (or any other
                  \n similar contracts) relating to oil and gas sector or other mining
                  \n sector concluded by each of the Contracting States.<\/p>\n<\/li>\n<\/ol>\n

                  Article
                  \n 11
                  \n INTEREST<\/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 12% of the gross amount of
                    \n the interest.<\/p>\n<\/li>\n

                  3. \n

                    Notwithstanding paragraphs 1 and
                    \n 2,
                    \n interest shall be exempt from tax in the Contracting State in which it
                    \n arises if the interest is:\n <\/p>\n\n\n\n\n
                    (a)<\/td>\n\n

                    beneficially derived by the
                    \n 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;<\/p>\n<\/td>\n<\/tr>\n

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

                    paid by the Government of
                    \n that Contracting State or a political subdivision or by the local
                    \n authority thereof to a resident of the other Contracting State, when
                    \n the maturity of this interest-generating loan is at least 7 years.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                    \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 a mortgage, and whether or not carrying a right to
                    \n participate in the debtor’s profits, and in particular, income from
                    \n government securities and income from bonds or debentures, including
                    \n premiums and prizes attaching to such securities, bonds or debentures.<\/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 the 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 person, 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
                    \n 12
                    \n ROYALTIES<\/p>\n

                      \n
                    1. \n

                      Royalties 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 royalties may be
                      \n also
                      \n taxed in the Contracting State in which they arise and according to the
                      \n laws of that State, but if the recipient is the beneficial owner of the
                      \n royalties, the tax so charged shall not exceed 15% of the gross amount
                      \n of the royalties.<\/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 film, and films or tapes for
                      \n radio or television broadcasting), any patent, trade mark, design or
                      \n model, plan, secret formula or process or for the use of, or the right
                      \n to use, agricultural, industrial, commercial or scientific equipment,
                      \n or for information concerning industrial, commercial or experience, or
                      \n for technical or economic studies, or for technical assistance.<\/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 14, as the case may be,
                      \n 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 State itself, a political
                      \n sub-division, a local authority or a resident of that State. Where,
                      \n however, the person paying the royalties, whether he is a resident of a
                      \n Contracting State or not, has in a Contracting State a permanent
                      \n establishment or fixed base in connection with which the liability to
                      \n pay the royalties was incurred, and such royalties are borne by such
                      \n permanent establishment or fixed base, then such royalties shall be
                      \n deemed to arise in the State in which the permanent establishment or
                      \n 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 person, 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 payment 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
                      \n 13
                      \n CAPITAL GAINS<\/p>\n

                        \n
                      1. \n

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

                      2. \n

                        Gains from the alienation of
                        \n movable property forming part of the business property of a permanent
                        \n establishment which an enterprise of a Contracting State has in the
                        \n other Contracting State or of movable property pertaining to a fixed
                        \n 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 gains from the alienation of such a permanent
                        \n establishment (alone or with the whole enterprise) or of such fixed
                        \n base, may be taxed in that other State.<\/p>\n<\/li>\n

                      3. \n

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

                      4. \n

                        Gains from the alienation of any
                        \n property other than that referred to in the 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
                        \n 14
                        \n INDEPENDENT PERSONAL SERVICES<\/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 he has a fixed base regularly available to him in the
                          \n other Contracting State for the purpose of performing his activities or
                          \n he is present in that other State for a period or periods exceeding in
                          \n the aggregate 120 days in any taxable year.<\/p>\n

                          If he has such a fixed base or remains in that other State for the
                          \n aforesaid period or periods, the income may be taxed in that other
                          \n State but only so much of it as is attributable to that fixed base or
                          \n is derived in that other State during the aforesaid period or periods.<\/p>\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
                          \n 15
                          \n DEPENDENT PERSONAL SERVICES<\/p>\n

                            \n
                          1. \n

                            Subject to the provisions of
                            \n Articles 16, 18, 19 and 20, 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
                            \n that other State for a period or periods not exceeding in the aggregate
                            \n 183 days in the calendar year; and<\/p>\n<\/td>\n<\/tr>\n

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

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

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

                            the remuneration is not borne
                            \n by a permanent establishment or a fixed base which the employer has in
                            \n 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 shall be
                            \n taxable only in that State. <\/p>\n<\/li>\n<\/ol>\n

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

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

                            Article
                            \n 17
                            \n ARTISTES AND ATHLETES<\/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 form 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 in that State are wholly or substantially
                              \n supported by funds of the other Contracting State, one of the local
                              \n authorities or of the public institutions..<\/p>\n<\/li>\n<\/ol>\n

                              Article
                              \n 18
                              \n PENSIONS<\/p>\n

                              Subject to the provisions of
                              \n paragraph
                              \n 2 of Article 19, pensions and other similar remuneration paid to a
                              \n resident of a Contracting State in consideration of past employment
                              \n shall be taxable only in that State, except that, if they are derived
                              \n from sources within the other Contracting State they may also be taxed
                              \n in that other State<\/p>\n

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

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

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

                              However, such remuneration shall
                              \n be taxable only in the other Contracting State if the services are
                              \n rendered in that other State and the individual is a resident of that
                              \n 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
                              \n State solely for the 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
                              \n funds created by, a Contracting State or a political subdivision or a
                              \n local authority thereof to an individual in respect of services
                              \n rendered to that State or subdivision or authority shall be taxable
                              \n only in that State.<\/p>\n<\/td>\n<\/tr>\n

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

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

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

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

                              Article
                              \n 20
                              \n PAYMENTS RECEIVED BY STUDENTS AND APPRENTICES<\/p>\n

                                \n
                              1. \n

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

                              2. \n

                                Notwithstanding the provisions
                                \n of
                                \n paragraph 1, remuneration which a student or business apprentice who is
                                \n or was formerly a resident of a Contracting State and who is present in
                                \n the other Contracting State solely for the purpose of his education or
                                \n training derives from services rendered in that other State shall not
                                \n be taxed in that other State in the limit of 3,000 US dollars or its
                                \n equivalent in Tunisian Dinars or in Indonesian Rupiahs in any calendar
                                \n year, provided that the remuneration of such services is necessary to
                                \n supplement the resources available to him for the purpose of his
                                \n maintenance.<\/p>\n<\/li>\n<\/ol>\n

                                Article
                                \n 21
                                \n OTHER INCOME<\/p>\n

                                  \n
                                1. \n

                                  Items of income of a resident of
                                  \n a
                                  \n Contracting State, wherever arising, not dealt with in the foregoing
                                  \n Articles of this Agreement shall be taxable only in that State.<\/p>\n<\/li>\n

                                2. \n

                                  Notwithstanding the provisions
                                  \n of
                                  \n paragraph 1, items of income of a resident of a Contracting State not
                                  \n dealt with in the foregoing articles of this Agreement and arising in
                                  \n the other Contracting State may also be taxed in that other State.e.<\/p>\n<\/li>\n<\/ol>\n

                                  Article
                                  \n 22
                                  \n RELIEF FROM DOUBLE TAXATION<\/p>\n

                                  Double taxation shall be avoided in
                                  \n the
                                  \n following manner <\/p>\n

                                    \n
                                  1. \n

                                    In the case of Tunisia :\n <\/p>\n

                                    Where
                                    \n a resident of Tunisia
                                    \n derives income which, in accordance with the provisions of this
                                    \n Agreement, may be taxed in Indonesia, Tunisia shall subject to the
                                    \n provisions of its domestic tax law, allow as a deduction from the tax
                                    \n on the income of that resident, an amount equal to the income tax paid
                                    \n in Indonesia. Such deduction shall not, however, exceed that part of
                                    \n the income tax, as computed before the deduction is given, which is
                                    \n attributable, as the case may be, to the income which may be taxed in
                                    \n Tunisia.<\/div>\n<\/li>\n
                                  2. \n

                                    In the case of Indonesia :\n <\/p>\n

                                    Where
                                    \n a resident of Indonesia
                                    \n derives income which, in accordance with the provisions of this
                                    \n Agreement, may be taxed in Tunisia, Indonesia shall subject to the
                                    \n provisions of its domestic tax law, allow as a deduction from the tax
                                    \n on the income of that resident, an amount equal to the income tax paid
                                    \n in Tunisia. Such deduction shall not, however, exceed that part of the
                                    \n income tax, as computed before the deduction is given, which is
                                    \n attributable, as the case may be, to the income which may be taxed in
                                    \n Indonesia.<\/div>\n<\/li>\n<\/ol>\n

                                    Article
                                    \n 23
                                    \n NON-DISCRIMINATION<\/p>\n

                                      \n
                                    1. \n

                                      Nationals of a Contracting State
                                      \n shall not be subjected in the other Contracting State to any taxation
                                      \n or any requirement connected therewith which is other or more
                                      \n burdensome than the taxation and connected requirements to which
                                      \n nationals of that other State in the same circumstances are or may be
                                      \n subjected. This provision shall, notwithstanding the provisions of
                                      \n Article 1, also apply to persons who are not residents of one or both
                                      \n of the Contracting States.<\/p>\n<\/li>\n

                                    2. \n

                                      The taxation on a permanent
                                      \n establishment which an enterprise of a Contracting State has in the
                                      \n other Contracting State shall not be less favourably levied in that
                                      \n other State than the taxation levied on enterprises of that other State
                                      \n carrying on the same activities.  <\/p>\n

                                      This provision shall not be construed as obliging a Contracting State
                                      \n to grant to residents of the other Contracting State any personal
                                      \n allowances, reliefs and reductions for taxation purposes on account of
                                      \n civil status or family responsibilities which it grants to its own
                                      \n residents.<\/p>\n<\/li>\n

                                    3. \n

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

                                    4. \n

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

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

                                        \n
                                      1. \n

                                        Where a person considers that
                                        \n the
                                        \n actions of one or both of the Contracting States result or will result
                                        \n for him in taxation not in accordance with the provisions of this
                                        \n Agreement, he may, irrespective of the remedies provided by the
                                        \n domestic law of those States, present his case to the competent
                                        \n authority of the Contracting State of which he is a resident or, if his
                                        \n case comes under paragraph 1 of Article 23, to that of the Contracting
                                        \n State of which he is a national. The case must be presented within
                                        \n three years form the first notification of the action resulting in
                                        \n taxation not in accordance with the provisions of the Agreement.<\/p>\n<\/li>\n

                                      2. \n

                                        The competent authority shall
                                        \n endeavour, 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 Convention.<\/p>\n<\/li>\n

                                      3. \n

                                        The competent authorities of the
                                        \n Contracting States shall endeavour to resolve by mutual agreement any
                                        \n difficulties or doubts arising as to the interpretation or application
                                        \n of the Convention. They may also consult together for the elimination
                                        \n of 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 reaching an agreement in the sense of the preceding
                                        \n paragraphs. When it seems advisable in order to reach agreement to have
                                        \n an oral exchange of opinions, such exchange may take place through a
                                        \n Commission consisting of representatives of the competent authorities
                                        \n of the Contracting States.<\/p>\n<\/li>\n<\/ol>\n

                                        Article
                                        \n 25
                                        \n EXCHANGE OF INFORMATION<\/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 States 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 be provisions
                                          \n of
                                          \n paragraph 1 be construed so as to impose on a Contracting State the
                                          \n obligation:\n <\/p>\n\n\n\n\n\n
                                          (a)<\/td>\n\n

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

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

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

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

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

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

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

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

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

                                            \n
                                          1. \n

                                            Each Contracting State shall
                                            \n notify
                                            \n to the other the completion of the procedure required by its law for
                                            \n the bringing into force of this Agreement. This Agreement shall enter
                                            \n into force one month after the date of the later of these notifications.<\/p>\n<\/li>\n

                                          2. \n

                                            Its provisions shall apply for
                                            \n the
                                            \n first time :\n <\/p>\n\n\n\n\n
                                            (i)<\/td>\n\n

                                            in respect of taxes withheld
                                            \n at source on income paid or credited, on or after 1 January in the
                                            \n calendar year next following that in which the Agreement enters into
                                            \n force; and<\/p>\n<\/td>\n<\/tr>\n

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

                                            in respect of other taxes on
                                            \n income, for taxable years beginning on or after 1 January in the
                                            \n calendar year next following that in which the Agreement enters into
                                            \n force.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

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

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

                                            This Agreement shall remain in force
                                            \n until terminated by a Contracting State. Either of the Contracting
                                            \n States may, on or before the thirtieth day of June in any calendar year
                                            \n from the fifth year following that in which the Agreement enters into
                                            \n force, give to the other Contracting State, through diplomatic
                                            \n channels, written notice of termination and, in such event, this
                                            \n Agreement shall cease to have effect:<\/p>\n\n\n\n\n
                                            (a)<\/td>\n\n

                                            in respect of tax withheld at
                                            \n the source on amounts paid or credited to non-residents on or after the
                                            \n first day of January in the calendar year next following that in which
                                            \n the notice is given; and<\/p>\n<\/td>\n<\/tr>\n

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

                                            in respect of other taxes, for
                                            \n taxable years beginning on or after the first day of January in the
                                            \n calendar year next following that in which the notice is given.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                            \n In witness whereof the undersigned, being duly authorized thereto by
                                            \n their respective Governments, have signed this Agreement.<\/div>\n
                                            \n
                                             <\/div>\n

                                            Done in duplicate at Denpasar this thirteenth day of May of the year
                                            \n one thousand nine hundred and ninety two in the Indonesian, Arabic,
                                            \n French and English languages and in case there is any divergency of
                                            \n interpretation, the English text shall prevail.<\/p>\n

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

                                            FOR THE GOVERNMENT OF THE
                                            \n REPUBLIC OF INDONESIA<\/p>\n

                                            ALI ALATAS<\/p>\n<\/td>\n

                                            		\n

                                            FOR THE GOVERNMENT OF THE
                                            \n REPUBLIC OF TUNISIA<\/p>\n

                                            HABIB BEN YAHIA<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table><\/div>\n<\/p><\/div>\n","protected":false},"excerpt":{"rendered":"

                                            AGREEMENT BETWEEN THE REPUBLIC OF INDONESIA AND THE REPUBLIC OF TUNISIA 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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