{"id":489,"date":"2025-10-01T03:32:21","date_gmt":"2025-10-01T03:32:21","guid":{"rendered":"https:\/\/whimsical-pyramid.localsite.io\/?p=489"},"modified":"2025-10-01T03:32:21","modified_gmt":"2025-10-01T03:32:21","slug":"turkey","status":"publish","type":"post","link":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/","title":{"rendered":"Turkey"},"content":{"rendered":"
\n
\n

AGREEMENT
\n BETWEEN
\n THE GOVERNMENT OF THE REPUBLIC OF INDONESIA
\n AND
\n THE GOVERNMENT OF THE REPUBLIC OF TURKEY<\/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 State.<\/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 Contracting State or of its political
    \n subdivisions or local authorities, irrespective of the manner in which
    \n they are levied.<\/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 [and] taxes on the total amounts of wages or salaries paid by
    \n enterprises.<\/p>\n<\/li>\n

  3. \n

    The existing taxes to which the
    \n Agreement shall apply are in particular:\n <\/p>\n\n\n\n\n\n\n\n\n
    (a)<\/td>\nin
    \n Turkey:<\/td>\n<\/tr>\n
    (i)<\/td>\nthe
    \n income
    \n tax;<\/td>\n<\/tr>\n
    (ii)<\/td>\nthe
    \n corporation tax;<\/td>\n<\/tr>\n
    (iii)<\/td>\nthe
    \n levy
    \n imposed on the income tax and the corporation tax;<\/td>\n<\/tr>\n
    (hereinafter
    \n referred to as Turkish tax”).<\/td>\n<\/tr>\n
    (b)<\/td>\nin Indonesia:
    \n the income tax imposed under the Undang-undang Pajak Ponghasilan 1984
    \n (Law no. 7 of 1983 as amended)<\/p>\n
    (hereinafter referred to
    \n as “Indonesian tax”).<\/div>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

    \n<\/li>\n

  4. \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 significant changes which have been made in
    \n 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\n
      (a)\n <\/td>\n(i)<\/td>\n\n

      the term “Turkey” means the
      \n Turkish territory, territorial sea, as well as the maritime areas over
      \n which it has jurisdiction or sovereign rights for the purpose of
      \n exploring, exploiting, conserving and managing natural resources,
      \n pursuant to international law;<\/p>\n<\/td>\n<\/tr>\n

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

      the term “Indonesia”
      \n comprises the territory of the Republic of Indonesia and the adjacent
      \n areas over which the Republic of Indonesia has sovereignty, sovereign
      \n rights or jurisdiction in accordance with international law;<\/p>\n<\/td>\n<\/tr>\n

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

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

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

      the term “tax” means any tax
      \n covered by Article 2 of this Agreement;<\/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 term registered office
      \n means the place of incorporation under the laws of Indonesia or the
      \n legal head office registered under the Turkish Code of Commerce;<\/p>\n<\/td>\n<\/tr>\n

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

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

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

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

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

      any legal person, partnership
      \n and association deriving its status as such from the laws in force in a
      \n Contracting State;<\/p>\n<\/td>\n<\/tr>\n

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

      the terms “enterprise of a
      \n Contracting State” and “enterprise of the other Contracting State” mean
      \n respectively an enterprise carried on by a resident of a Contracting
      \n State and an enterprise carried on by a resident of the other
      \n 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 Turkey, the Minister of
      \n Finance or his authorized representative, and<\/p>\n<\/td>\n<\/tr>\n

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

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

      (j)<\/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<\/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 purposes 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, registered office, legal head office, place of
        \n management or any other criterion of a similar nature.<\/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:<\/p>\n

          \n
        1. \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<\/li>\n

        2. \n

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

        3. \n

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

        4. \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<\/li>\n<\/ol>\n<\/li>\n

        5. \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 it has been incorporated (registered).<\/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:<\/p>\n

              \n
            1. \n

              a place of management;<\/p>\n<\/li>\n

            2. \n

              a branch;<\/p>\n<\/li>\n

            3. \n

              an office;<\/p>\n<\/li>\n

            4. \n

              a factory;<\/p>\n<\/li>\n

            5. \n

              a workshop; and<\/p>\n<\/li>\n

            6. \n

              a mine, an oil or gas well,
              \n a
              \n quarry or any other place of extraction of natural resources.<\/p>\n<\/li>\n<\/ol>\n<\/li>\n

            7. \n

              The term “permanent
              \n establishment”
              \n likewise encompasses:<\/p>\n

                \n
              1. \n

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

              2. \n

                the furnishing of services,
                \n including consultancy services by an enterprise through employees or
                \n other personnel engaged by the enterprise for such purpose, but only
                \n where activities of that nature continue (for the same or a connected
                \n project) within the country for a period or periods aggregating more
                \n than 183 days within any twelve-month period.<\/p>\n<\/li>\n<\/ol>\n<\/li>\n

              3. Notwithstanding the preceding provisions of this
                \n Article,
                \n the term “permanent establishment” shall be deemed not to include:<\/p>\n
                  \n
                1. \n

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

                2. \n

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

                3. \n

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

                4. \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<\/li>\n

                5. \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<\/li>\n

                6. \n

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

                7. \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:<\/p>\n

                    \n
                  1. \n

                    has and habitually exercises
                    \n in
                    \n 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<\/li>\n

                  2. \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 on behalf of the
                    \n enterprise.<\/p>\n<\/li>\n<\/ol>\n<\/li>\n

                  3. \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 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

                  4. \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 of otherwise), shall not of itself constitute either company a
                    \n permanent establishment of the other.<\/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 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 (including the breeding and cultivation
                      \n of fish) and forestry, rights to which the provisions of general law
                      \n respecting landed property apply, usufruct of immovable property and
                      \n rights to variable or fixed payments as consideration for the working
                      \n of, or the right to work, mineral deposits, sources and other natural
                      \n resources; ships, boats and aircraft shall not be regarded as immovable
                      \n property.<\/p>\n<\/li>\n

                    3. \n

                      The provisions of paragraph 1
                      \n shall
                      \n apply to income derived from the direct use, letting, or use in any
                      \n 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 that
                        \n permanent establishment.<\/p>\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. However, no such deduction will be allowed in respect of
                        \n participations to the expenses and losses of the head office or other
                        \n permanent establishments situated abroad and, likewise, the amounts
                        \n paid by the permanent establishment to the head office of the
                        \n enterprise [or] any of its other permanent establishments, by way of
                        \n royalties, interests, commissions or other similar payments.<\/p>\n<\/li>\n

                      4. \n

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

                      5. \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 derived by an enterprise
                          \n of
                          \n a 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

                          For the purposes of this
                          \n Article,
                          \n profits derived by an enterprise of a Contracting State from the
                          \n operation of ships or aircraft in international traffic shall include
                          \n inter alia profits derived from the use or rental of containers, if
                          \n such profits are incidental to the profits to which the provisions of
                          \n paragraph 1 apply.<\/p>\n<\/li>\n

                        3. \n

                          The provisions of paragraph 1 of
                          \n this Article shall also apply to profits from the participation in a
                          \n pool, a joint business or an international operating agency.<\/p>\n<\/li>\n<\/ol>\n

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

                            \n
                          1. \n

                            Where<\/p>\n

                              \n
                            1. \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<\/li>\n

                            2. \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<\/li>\n<\/ol>\n

                              and
                              \n in either case conditions
                              \n are made or imposed between the two enterprises in their commercial or
                              \n financial relations which differ from 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.<\/div>\n

                              \n<\/li>\n

                            3. \n

                              Where a Contracting State
                              \n includes
                              \n in the profits of an enterprise of that State — and taxes accordingly
                              \n — profits on which an enterprise of the other Contracting State has
                              \n been charged to tax in that other State and the profits so included are
                              \n by the first-mentioned State claimed to be profits which would have
                              \n accrued to the enterprise of the first-mentioned State if the
                              \n conditions made between the two enterprises had been those which would
                              \n have been made between independent enterprises, then that other State
                              \n shall make an appropriate adjustment to the amount of the tax charged
                              \n therein on those profits, where that other State considers the
                              \n adjustment justified. In determining such adjustment, due regard shall
                              \n be had to the other provisions of this Agreement and the competent
                              \n authorities of the Contracting States shall if necessary consult each
                              \n other.<\/p>\n<\/li>\n<\/ol>\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:<\/p>\n

                                  \n
                                1. \n

                                  10 per cent of the gross
                                  \n amount
                                  \n of the dividends if the beneficial owner is a company (excluding
                                  \n partnership) which holds directly at least 25 per cent of the capital
                                  \n of the company paying the dividends;<\/p>\n<\/li>\n

                                2. \n

                                  15 per cent of the gross
                                  \n amount
                                  \n of the dividends in all other cases.<\/p>\n<\/li>\n<\/ol>\n<\/li>\n

                                3. \n

                                  The term “dividends” as used in
                                  \n this Article means income from shares, “jouissance” shares or
                                  \n “jouissance” rights, founders’ 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, and income derived from an investment
                                  \n fund and investment trust.<\/p>\n<\/li>\n

                                4. \n

                                  Profits of a company of a
                                  \n Contracting State carrying on business in the other Contracting State
                                  \n through a permanent establishment situated therein may, after having
                                  \n been taxed under Article 7, be taxed on the remaining amount in the
                                  \n Contracting State in which the permanent establishment is situated and
                                  \n in accordance with paragraph 2 of 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 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 in the
                                  \n case of a resident of Turkey, performs in Indonesia independent
                                  \n personal services from a fixed base situated in Indonesia, and the
                                  \n holding in respect of which the dividends are paid is effectively
                                  \n connected with such permanent establishment or fixed base. In such case
                                  \n the provisions of Article 7 or Article 14, as the case may be, shall
                                  \n apply.<\/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 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:\n <\/p>\n\n\n\n\n
                                    (a)<\/td>\n\n

                                    Indonesia and paid to the
                                    \n Government of Turkey or to the Central Bank of Turkey (Turkiye
                                    \n Cumhuriyet Merkez Bankasy) or to the Turkish Eximbank (Turkiye Yhracat
                                    \n Kredi Bankasy A.S.) shall be exempt from Indonesian tax;<\/p>\n<\/td>\n<\/tr>\n

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

                                    Turkey and paid to the
                                    \n Government of Indonesia or to the Bank of Indonesia (Central Bank)
                                    \n shall be exempt from Turkish tax.<\/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 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 interest on
                                    \n deferred payment sales<\/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 in the case of a resident of Turkey,
                                    \n performs in Indonesia independent personal services from a fixed base
                                    \n situated in Indonesia, and the debt-claim in respect of which the
                                    \n interest is 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

                                  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 also
                                      \n be
                                      \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 10 per cent of the gross
                                      \n amount of the royalties. 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

                                      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 and recordings for radio
                                      \n and television, any patent, trade mark, design or model, plan, secret
                                      \n formula or process, or for information concerning industrial,
                                      \n commercial or scientific experience, or for the use of, or the right to
                                      \n use, industrial, commercial or scientific equipment.<\/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 in the case of a resident of Turkey
                                      \n performs in Indonesia independent personal services from a fixed base
                                      \n situated in Indonesia, and the right or property in respect of which
                                      \n the royalties 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

                                      Royalties 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 royalties, 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 right or
                                      \n property giving rise to the royalties is effectively connected, and
                                      \n such royalties are borne by such permanent establishment or fixed base,
                                      \n then such royalties shall be deemed to arise in the State in which the
                                      \n permanent 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 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 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
                                      \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 paragraphs 1, 2 and 3, shall be
                                        \n taxable only in the Contracting State of which the alienator is a
                                        \n resident. However, the capital gains mentioned in the foregoing
                                        \n sentence and derived from the other Contracting State shall be taxable
                                        \n in the other Contracting State if the time period does not exceed one
                                        \n year between acquisition and alienation.<\/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 183 days within any twelve-month period. If he has such a
                                          \n fixed base or remains in that other State for the aforesaid period or
                                          \n periods, the income may be taxed in that other State but only so much
                                          \n of it as is attributable to that fixed base or is derived in that other
                                          \n 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,
                                            \n wages and other similar remuneration derived by a resident of a
                                            \n Contracting State in respect of an employment shall be taxable only in
                                            \n that State unless the employment is exercised in the other Contracting
                                            \n State. If the employment is so exercised, such remuneration as is
                                            \n derived therefrom may be taxed in 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 the other State for a period or periods not exceeding in the aggregate
                                            \n 183 days within any twelve month period; 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’
                                            \n 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 of a company which is a resident
                                            \n of the other Contracting State may be taxed in that other State.<\/div>\n

                                            Article
                                            \n 17
                                            \n ARTISTS AND SPORTSMEN<\/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 a sportsman, 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 a sportsman in his capacity
                                              \n as such accrues not to the entertainer or sportsman himself but to
                                              \n another person, that income may, notwithstanding the provisions of
                                              \n Article 7, 14 and 15, be taxed in the Contracting State in which the
                                              \n activities of the entertainer or sportsman are exercised.<\/p>\n<\/li>\n

                                            3. \n

                                              Income derived by an entertainer
                                              \n or
                                              \n a sportsman from activities exercised in a Contracting State shall be
                                              \n exempt from tax in that State if the visit to that State is supported
                                              \n wholly or mainly by public funds of the other Contracting State, a
                                              \n political subdivision or a local authority thereof.<\/p>\n<\/li>\n<\/ol>\n

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

                                                \n
                                              1. \n

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

                                              2. \n

                                                Pensions and life annuities
                                                \n paid,
                                                \n and other periodical or occasional payments made by a Contracting
                                                \n State, or one of its political subdivisions in respect of insuring
                                                \n personal accidents, may be taxed in that State.<\/p>\n<\/li>\n

                                              3. \n

                                                The term “annuity” means a
                                                \n stated
                                                \n 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<\/li>\n<\/ol>\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 subdivision or authority shall be taxable
                                                \n 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 not solely for the purpose of rendering the service.<\/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 State.<\/p>\n<\/td>\n<\/tr>\n

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

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

                                                Article
                                                \n 20
                                                \n TEACHERS AND STUDENTS<\/p>\n

                                                  \n
                                                1. \n

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

                                                2. \n

                                                  Likewise, remuneration received
                                                  \n by
                                                  \n a teacher or by an instructor who is a national of a Contracting State
                                                  \n and who is present in the other Contracting State [for] the primary
                                                  \n purpose of teaching or engaging in scientific research for a period or
                                                  \n periods not exceeding two consecutive years shall be exempt from tax in
                                                  \n that other State on his remuneration from personal services for
                                                  \n teaching or research, provided that such payments arise from sources
                                                  \n outside that other State.<\/p>\n<\/li>\n

                                                3. \n

                                                  Remuneration which a student or
                                                  \n a
                                                  \n trainee who is a national of a Contracting State derives from an
                                                  \n employment which he exercises in the other Contracting State for a
                                                  \n period or periods not exceeding 183 days in a calendar year in order to
                                                  \n obtain practical experience related to his education or formation shall
                                                  \n not be taxed in that other State.<\/p>\n<\/li>\n<\/ol>\n

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

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

                                                  Article
                                                  \n 22
                                                  \n ELIMINATION OF DOUBLE TAXATION<\/p>\n

                                                    \n
                                                  1. \n

                                                    Double taxation for the
                                                    \n residents
                                                    \n of Indonesia shall be eliminated as follows : \n <\/p>\n\n\n\n\n
                                                    (a)<\/td>\nWhere
                                                    \n a resident of Turkey derives income which, exclusive of income covered
                                                    \n by paragraph (b) hereafter, in accordance with the provisions of this
                                                    \n Agreement, may be taxed in Indonesia, Turkey shall exempt such income
                                                    \n from tax but may, in calculating tax on the remaining income of that
                                                    \n person, apply the rate of tax which would have been applicable if the
                                                    \n exempted income had not been so exempted.<\/td>\n<\/tr>\n
                                                    (b)<\/td>\nWhere
                                                    \n a resident of Turkey derives income which, in accordance with the
                                                    \n provisions of Articles 10, 11, 12 and paragraph 4 of Article 13 of this
                                                    \n Agreement, may be taxed in Indonesia, Turkey shall allow as a deduction
                                                    \n from the tax on the income of that person, an amount equal to the tax
                                                    \n paid in Indonesia. <\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                                    Such deductions shall not,
                                                    \n however,
                                                    \n exceed that part of the tax, as computed before the deduction is given,
                                                    \n which is appropriate to the income [which] may be taxed in Indonesia.<\/p>\n<\/li>\n

                                                  2. \n

                                                    Double taxation for the
                                                    \n residents
                                                    \n of Indonesia shall be eliminated as follows: Where a resident of
                                                    \n Indonesia derives income from Turkey, the amount of tax on that income
                                                    \n payable in Turkey, in accordance with the provisions of this Agreement,
                                                    \n may be credited against the tax levied in Indonesia imposed on that
                                                    \n resident. The amount of credit, however, shall not exceed the amount of
                                                    \n the tax in Indonesia on that income computed in accordance with its
                                                    \n taxation laws and regulations\n <\/p>\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, in particular
                                                      \n with respect to residence, are or may be subjected<\/p>\n<\/li>\n

                                                    2. \n

                                                      Subject to the provisions of
                                                      \n paragraph 4 of Article 10, the taxation on a permanent establishment
                                                      \n which an enterprise of a Contracting State has in the other Contracting
                                                      \n State shall not be less favourably levied in that other State than the
                                                      \n taxation levied on enterprises of that other State carrying on the same
                                                      \n activities.<\/p>\n<\/li>\n

                                                    3. \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

                                                    4. \n

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

                                                      Article
                                                      \n 24
                                                      \n MUTUAL AGREEMENT PROCEDURE<\/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 or, if his case comes under paragraph 1 of Article 23, to that of the
                                                        \n Contracting State of which he is a national.<\/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 Agreement.<\/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 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 reaching an agreement in the sense of the preceding
                                                        \n paragraphs. The competent authorities, through consultations, shall
                                                        \n develop appropriate bilateral procedures, conditions, methods and
                                                        \n techniques for the implementation of the mutual agreement procedure
                                                        \n provided for in this Article.<\/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 Any information received by a Contracting State shall be treated as
                                                          \n secret in the same manner as information obtained under the domestic
                                                          \n laws of that State and shall be disclosed only to persons or
                                                          \n authorities (including courts and administrative bodies) involved in
                                                          \n the assessment or collection of, the enforcement or prosecution in
                                                          \n respect of, or the determination of appeals in relation to, the taxes
                                                          \n covered by the Agreement. Such persons or authorities shall use the
                                                          \n information only for such purposes. They may disclose the information
                                                          \n in public court 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 State
                                                          \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

                                                          to 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 MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS<\/p>\n

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

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

                                                            \n
                                                          1. \n

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

                                                          2. \n

                                                            The provisions of this
                                                            \n Agreement
                                                            \n shall have effect :\n <\/p>\n\n\n\n\n
                                                            (a)<\/td>\n\n

                                                            with regard to taxes withheld
                                                            \n at source, in respect of amounts paid or credited on or after the first
                                                            \n day of January next following the date upon which this Agreement enters
                                                            \n into force; and<\/p>\n<\/td>\n<\/tr>\n

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

                                                            with regard to other taxes,
                                                            \n in respect of taxable years beginning on or after the first day of
                                                            \n January next following the date upon which this 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 Contracting State may
                                                            \n terminate the Agreement, through diplomatic channels, by giving notice
                                                            \n of termination at least six months before the end of any calendar year
                                                            \n beginning after the expiration of five years from the date of entry
                                                            \n into force of the Agreement. In such event, the Agreement shall cease
                                                            \n to have effect:<\/p>\n\n\n\n\n
                                                            (a)<\/td>\n\n

                                                            with regard to taxes withheld at
                                                            \n source, in respect of amounts paid or credited on or after the first
                                                            \n day of January next following the date upon which such notice is given;
                                                            \n and<\/p>\n<\/td>\n<\/tr>\n

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

                                                            with regard to other taxes, in
                                                            \n respect of taxable years beginning on or after the first day of January
                                                            \n next following the date upon which such notice is given.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                                            \n In witness whereof, the
                                                            \n undersigned, duly authorized thereto, have signed the present Agreement
                                                            \n and have affixed their seals thereto.<\/div>\n
                                                            \n
                                                             <\/div>\n
                                                            Done in duplicate at
                                                            \n Jakarta this 25th day of February 1997 in the
                                                            \n Turkish, Indonesian and English languages, all three texts being
                                                            \n equally authentic. In case of divergence between the texts, the English
                                                            \n text shall be the operative one.\n <\/div>\n
                                                            PROTOCOL<\/p>\n
                                                            <\/div>\n
                                                            <\/div>\n<\/p><\/div>\n
                                                            At
                                                            \n the time of signing the
                                                            \n Agreement for the Avoidance of Double Taxation and the Prevention of
                                                            \n Fiscal Evasion with respect to taxes on income, concluded this day
                                                            \n between the Republic of Indonesia and the Republic of Turkey, the
                                                            \n undersigned have agreed that the following provisions shall form an
                                                            \n integral part of the Agreement.<\/div>\n

                                                            <\/p>\n

                                                            \n
                                                            1.<\/span>With respect to Article
                                                            \n 5:<\/span>\n <\/div>\n<\/p><\/div>\n
                                                            \n
                                                             <\/div>\n
                                                            It is understood that
                                                            \n the use of facilities solely for the purpose of
                                                            \n mere delivery of goods or merchandise and the maintenance of a stock of
                                                            \n goods or merchandise solely for the purpose of mere delivery shall not
                                                            \n be treated as permanent establishment for the purposes of this
                                                            \n Agreement. On the contrary, the regular delivery in such cases and in
                                                            \n the cases of activities of a person other than acting as an agent of an
                                                            \n independent status on behalf of an enterprise and who habitually
                                                            \n maintains a stock of goods or merchandise in the other Contracting
                                                            \n State, shall be deemed to be a permanent establishment for the purposes
                                                            \n of this Agreement.<\/div>\n<\/p><\/div>\n

                                                            <\/p>\n

                                                            \n
                                                            2.<\/span>With respect to Article
                                                            \n 10:<\/span>\n <\/div>\n<\/p><\/div>\n
                                                            \n
                                                             <\/div>\n
                                                            The provisions of
                                                            \n paragraph 4 of this Article shall not affect the
                                                            \n provisions contained in any production sharing contracts or any other
                                                            \n similar contracts relating to [the] oil and gas sector or other mining
                                                            \n sector concluded by the Government of Indonesia, its instrumentality,
                                                            \n its relevant state oil and gas company or any other entity thereof with
                                                            \n a person who is a resident of Turkey.<\/div>\n<\/p><\/div>\n
                                                            \n
                                                             <\/div>\n
                                                            3.<\/span>With respect to Article
                                                            \n 16:<\/span>\n <\/div>\n<\/p><\/div>\n
                                                            \n
                                                             <\/div>\n
                                                            The term “a member of
                                                            \n the board of directors of company” shall include
                                                            \n managing directors (anggota pengurus) and supervisory directors
                                                            \n (anggota dewan komisaris) of an Indonesia company.<\/div>\n<\/p><\/div>\n
                                                            \n
                                                             <\/div>\n
                                                            4.<\/span>With respect to Article
                                                            \n 24:<\/span>\n <\/div>\n<\/p><\/div>\n
                                                            \n
                                                             <\/div>\n
                                                            For the purposes of
                                                            \n paragraph 3 of Article XXII (Consultation) of the
                                                            \n General Agreement on Trade in Services, the Contracting States agree
                                                            \n that, notwithstanding that paragraph, any dispute between them as to
                                                            \n whether a measure falls within the scope of this Agreement may be
                                                            \n brought before the Council for Trade in Services, as provided by that
                                                            \n paragraph, only with the consent of both Contracting States. Any doubt
                                                            \n as to the interpretation of this paragraph shall be resolved under
                                                            \n paragraph 3 of Article 24 or, failing agreement under that procedure,
                                                            \n pursuant to any other procedure agreed by both Contracting States.<\/div>\n<\/p><\/div>\n
                                                            <\/div>\n
                                                            \n
                                                            In
                                                            \n witness whereof, the undersigned duly authorized thereto have signed
                                                            \n the present Protocol and have affixed their seals thereto.<\/div>\n
                                                            <\/div>\n
                                                            \n
                                                            Done in duplicate at
                                                            \n Jakarta this 25th day of February 1997 in the
                                                            \n Turkish, Indonesian and English languages, all three texts being
                                                            \n equally authentic. In case of divergence between the texts, the English
                                                            \n text shall be the operative one.<\/p>\n

                                                            \n <\/div>\n

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

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

                                                            		\n

                                                            FOR THE GOVERNMENT OF
                                                            \n THE REPUBLIC OF TURKEY
                                                            \n sgd<\/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 THE REPUBLIC OF TURKEY 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 […]<\/p>\n","protected":false},"author":1,"featured_media":287,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-489","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-uncategorized"],"yoast_head":"\nTurkey - Indonesia Tax Treaty Countries List<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Turkey - Indonesia Tax Treaty Countries List\" \/>\n<meta property=\"og:description\" content=\"AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND THE GOVERNMENT OF THE REPUBLIC OF TURKEY 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 […]\" \/>\n<meta property=\"og:url\" content=\"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/\" \/>\n<meta property=\"og:site_name\" content=\"Indonesia Tax Treaty Countries List\" \/>\n<meta property=\"article:published_time\" content=\"2025-10-01T03:32:21+00:00\" \/>\n<meta property=\"og:image\" content=\"https:\/\/investinasia.id\/education\/tax-treaty\/wp-content\/uploads\/2025\/09\/tr.webp\" \/>\n\t<meta property=\"og:image:width\" content=\"2560\" \/>\n\t<meta property=\"og:image:height\" content=\"1707\" \/>\n\t<meta property=\"og:image:type\" content=\"image\/webp\" \/>\n<meta name=\"author\" content=\"tax-treaty\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:label1\" content=\"Written by\" \/>\n\t<meta name=\"twitter:data1\" content=\"tax-treaty\" \/>\n\t<meta name=\"twitter:label2\" content=\"Est. reading time\" \/>\n\t<meta name=\"twitter:data2\" content=\"31 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\\\/\\\/schema.org\",\"@graph\":[{\"@type\":\"Article\",\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/turkey\\\/#article\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/turkey\\\/\"},\"author\":{\"name\":\"tax-treaty\",\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/#\\\/schema\\\/person\\\/59c6a9df910a745215faa4ea606ccadf\"},\"headline\":\"Turkey\",\"datePublished\":\"2025-10-01T03:32:21+00:00\",\"mainEntityOfPage\":{\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/turkey\\\/\"},\"wordCount\":6953,\"commentCount\":0,\"publisher\":{\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/#organization\"},\"image\":{\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/turkey\\\/#primaryimage\"},\"thumbnailUrl\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/wp-content\\\/uploads\\\/2025\\\/09\\\/tr.webp\",\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"CommentAction\",\"name\":\"Comment\",\"target\":[\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/turkey\\\/#respond\"]}]},{\"@type\":\"WebPage\",\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/turkey\\\/\",\"url\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/turkey\\\/\",\"name\":\"Turkey - Indonesia Tax Treaty Countries List\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/#website\"},\"primaryImageOfPage\":{\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/turkey\\\/#primaryimage\"},\"image\":{\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/turkey\\\/#primaryimage\"},\"thumbnailUrl\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/wp-content\\\/uploads\\\/2025\\\/09\\\/tr.webp\",\"datePublished\":\"2025-10-01T03:32:21+00:00\",\"breadcrumb\":{\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/turkey\\\/#breadcrumb\"},\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/turkey\\\/\"]}]},{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/turkey\\\/#primaryimage\",\"url\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/wp-content\\\/uploads\\\/2025\\\/09\\\/tr.webp\",\"contentUrl\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/wp-content\\\/uploads\\\/2025\\\/09\\\/tr.webp\",\"width\":2560,\"height\":1707},{\"@type\":\"BreadcrumbList\",\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/turkey\\\/#breadcrumb\",\"itemListElement\":[{\"@type\":\"ListItem\",\"position\":1,\"name\":\"Home\",\"item\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/\"},{\"@type\":\"ListItem\",\"position\":2,\"name\":\"Turkey\"}]},{\"@type\":\"WebSite\",\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/#website\",\"url\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/\",\"name\":\"Indonesia Tax Treaty Countries List\",\"description\":\"Find out the full list of countries that entered into a tax treaty with Indonesia here.\",\"publisher\":{\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/#organization\"},\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/?s={search_term_string}\"},\"query-input\":{\"@type\":\"PropertyValueSpecification\",\"valueRequired\":true,\"valueName\":\"search_term_string\"}}],\"inLanguage\":\"en-US\"},{\"@type\":\"Organization\",\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/#organization\",\"name\":\"Indonesia Tax Treaty Countries List\",\"url\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/\",\"logo\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/#\\\/schema\\\/logo\\\/image\\\/\",\"url\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/wp-content\\\/uploads\\\/2025\\\/09\\\/logo-iia-dark.webp\",\"contentUrl\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/wp-content\\\/uploads\\\/2025\\\/09\\\/logo-iia-dark.webp\",\"width\":1600,\"height\":430,\"caption\":\"Indonesia Tax Treaty Countries List\"},\"image\":{\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/#\\\/schema\\\/logo\\\/image\\\/\"}},{\"@type\":\"Person\",\"@id\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/#\\\/schema\\\/person\\\/59c6a9df910a745215faa4ea606ccadf\",\"name\":\"tax-treaty\",\"image\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/9ca67ce559dca519db131941b706e036c85cbca469cad6875d85e3696764a31b?s=96&d=mm&r=g\",\"url\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/9ca67ce559dca519db131941b706e036c85cbca469cad6875d85e3696764a31b?s=96&d=mm&r=g\",\"contentUrl\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/9ca67ce559dca519db131941b706e036c85cbca469cad6875d85e3696764a31b?s=96&d=mm&r=g\",\"caption\":\"tax-treaty\"},\"sameAs\":[\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\"],\"url\":\"https:\\\/\\\/investinasia.id\\\/education\\\/tax-treaty\\\/author\\\/tax-treaty\\\/\"}]}<\/script>\n<!-- \/ Yoast SEO plugin. -->","yoast_head_json":{"title":"Turkey - Indonesia Tax Treaty Countries List","robots":{"index":"index","follow":"follow","max-snippet":"max-snippet:-1","max-image-preview":"max-image-preview:large","max-video-preview":"max-video-preview:-1"},"canonical":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/","og_locale":"en_US","og_type":"article","og_title":"Turkey - Indonesia Tax Treaty Countries List","og_description":"AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND THE GOVERNMENT OF THE REPUBLIC OF TURKEY 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 […]","og_url":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/","og_site_name":"Indonesia Tax Treaty Countries List","article_published_time":"2025-10-01T03:32:21+00:00","og_image":[{"width":2560,"height":1707,"url":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-content\/uploads\/2025\/09\/tr.webp","type":"image\/webp"}],"author":"tax-treaty","twitter_card":"summary_large_image","twitter_misc":{"Written by":"tax-treaty","Est. reading time":"31 minutes"},"schema":{"@context":"https:\/\/schema.org","@graph":[{"@type":"Article","@id":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/#article","isPartOf":{"@id":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/"},"author":{"name":"tax-treaty","@id":"https:\/\/investinasia.id\/education\/tax-treaty\/#\/schema\/person\/59c6a9df910a745215faa4ea606ccadf"},"headline":"Turkey","datePublished":"2025-10-01T03:32:21+00:00","mainEntityOfPage":{"@id":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/"},"wordCount":6953,"commentCount":0,"publisher":{"@id":"https:\/\/investinasia.id\/education\/tax-treaty\/#organization"},"image":{"@id":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/#primaryimage"},"thumbnailUrl":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-content\/uploads\/2025\/09\/tr.webp","inLanguage":"en-US","potentialAction":[{"@type":"CommentAction","name":"Comment","target":["https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/#respond"]}]},{"@type":"WebPage","@id":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/","url":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/","name":"Turkey - Indonesia Tax Treaty Countries List","isPartOf":{"@id":"https:\/\/investinasia.id\/education\/tax-treaty\/#website"},"primaryImageOfPage":{"@id":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/#primaryimage"},"image":{"@id":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/#primaryimage"},"thumbnailUrl":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-content\/uploads\/2025\/09\/tr.webp","datePublished":"2025-10-01T03:32:21+00:00","breadcrumb":{"@id":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/#breadcrumb"},"inLanguage":"en-US","potentialAction":[{"@type":"ReadAction","target":["https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/"]}]},{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/#primaryimage","url":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-content\/uploads\/2025\/09\/tr.webp","contentUrl":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-content\/uploads\/2025\/09\/tr.webp","width":2560,"height":1707},{"@type":"BreadcrumbList","@id":"https:\/\/investinasia.id\/education\/tax-treaty\/turkey\/#breadcrumb","itemListElement":[{"@type":"ListItem","position":1,"name":"Home","item":"https:\/\/investinasia.id\/education\/tax-treaty\/"},{"@type":"ListItem","position":2,"name":"Turkey"}]},{"@type":"WebSite","@id":"https:\/\/investinasia.id\/education\/tax-treaty\/#website","url":"https:\/\/investinasia.id\/education\/tax-treaty\/","name":"Indonesia Tax Treaty Countries List","description":"Find out the full list of countries that entered into a tax treaty with Indonesia here.","publisher":{"@id":"https:\/\/investinasia.id\/education\/tax-treaty\/#organization"},"potentialAction":[{"@type":"SearchAction","target":{"@type":"EntryPoint","urlTemplate":"https:\/\/investinasia.id\/education\/tax-treaty\/?s={search_term_string}"},"query-input":{"@type":"PropertyValueSpecification","valueRequired":true,"valueName":"search_term_string"}}],"inLanguage":"en-US"},{"@type":"Organization","@id":"https:\/\/investinasia.id\/education\/tax-treaty\/#organization","name":"Indonesia Tax Treaty Countries List","url":"https:\/\/investinasia.id\/education\/tax-treaty\/","logo":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/investinasia.id\/education\/tax-treaty\/#\/schema\/logo\/image\/","url":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-content\/uploads\/2025\/09\/logo-iia-dark.webp","contentUrl":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-content\/uploads\/2025\/09\/logo-iia-dark.webp","width":1600,"height":430,"caption":"Indonesia Tax Treaty Countries List"},"image":{"@id":"https:\/\/investinasia.id\/education\/tax-treaty\/#\/schema\/logo\/image\/"}},{"@type":"Person","@id":"https:\/\/investinasia.id\/education\/tax-treaty\/#\/schema\/person\/59c6a9df910a745215faa4ea606ccadf","name":"tax-treaty","image":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/secure.gravatar.com\/avatar\/9ca67ce559dca519db131941b706e036c85cbca469cad6875d85e3696764a31b?s=96&d=mm&r=g","url":"https:\/\/secure.gravatar.com\/avatar\/9ca67ce559dca519db131941b706e036c85cbca469cad6875d85e3696764a31b?s=96&d=mm&r=g","contentUrl":"https:\/\/secure.gravatar.com\/avatar\/9ca67ce559dca519db131941b706e036c85cbca469cad6875d85e3696764a31b?s=96&d=mm&r=g","caption":"tax-treaty"},"sameAs":["https:\/\/investinasia.id\/education\/tax-treaty"],"url":"https:\/\/investinasia.id\/education\/tax-treaty\/author\/tax-treaty\/"}]}},"_links":{"self":[{"href":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-json\/wp\/v2\/posts\/489","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-json\/wp\/v2\/comments?post=489"}],"version-history":[{"count":1,"href":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-json\/wp\/v2\/posts\/489\/revisions"}],"predecessor-version":[{"id":490,"href":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-json\/wp\/v2\/posts\/489\/revisions\/490"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-json\/wp\/v2\/media\/287"}],"wp:attachment":[{"href":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-json\/wp\/v2\/media?parent=489"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-json\/wp\/v2\/categories?post=489"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/investinasia.id\/education\/tax-treaty\/wp-json\/wp\/v2\/tags?post=489"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}