Indonesia

Indonesia has 70 tax agreements in force as reported in its response to the Peer Review questionnaire. Twenty-one of those agreements comply with the minimum standard.

Indonesia signed the MLI in 2017 and deposited its instrument of ratification on 28 April 2020. The MLI entered into force for Indonesia on 1 August 2020. The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.

Indonesia reserved the right to delay the entry into effect of the provisions of the MLI until Indonesia has completed its internal procedures for this purpose with respect to each of its listed agreements.1 Indonesia notified that it completed its internal procedures for the entry into effect of the MLI with respect to its agreements with Australia, Belgium, Canada, Denmark, Finland, France, India, Japan, Korea, Luxembourg, Netherlands, New Zealand, Poland, Portugal, Qatar, the Russian Federation, Serbia, Singapore, the Slovak Republic, Sweden, the United Arab Emirates and the United Kingdom on 26 November 2020, and with respect to its agreements with Croatia, Egypt, Hungary, Malaysia and Pakistan on 21 October 2021.

Indonesia has not listed its agreements with, Austria, Belarus, Germany, Jordan, Mongolia, Morocco, Papua New Guinea, Sri Lanka, Tunisia and Ukraine under the MLI. These agreements will therefore not, at this stage, be modified by the MLI. Jordan, Morocco, Tunisia, Papua New Guinea and Ukraine have listed their agreements with Indonesia under the MLI. Indonesia indicated in its response to the Peer Review questionnaire that steps have been taken (other than under the MLI) to implement the minimum standard in its agreement with Austria and Germany. Indonesia indicated in its response to the Peer Review questionnaire that the agreements with Mongolia, Morocco, Papua New Guinea, Sri Lanka, Tunisia and Ukraine do not give rise to material treaty-shopping concerns for Indonesia.

Indonesia is implementing the minimum standard through the inclusion of the preamble statement and the PPT.2

Jordan, Morocco, Tunisia, Papua New Guinea and Ukraine have listed their agreements with Indonesia under the MLI, which amount to requests to implement the minimum standard.

Indonesia has developed a plan for the implementation of the minimum standard in its agreements with Belarus, Jordan, Mongolia, Morocco, Papua New Guinea, Sri Lanka, Tunisia and Ukraine. Indonesia indicated in its response to the Peer Review questionnaire that it intends to expand its list of agreements to be covered under the MLI to include those agreements.

← 1. The reservation was made under Article 35(7)(a) of the MLI.

← 2. For its agreements listed under the MLI, Indonesia is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI).

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