1. In 2019, BVI Inc a company incorporated in British Virgin Island, intended to lend some money to its Indonesian subsidiary. PT Indo, with fair interest rate. To do, firstly BVI Inc created another subsidiary, Mart Co, In Mauritius. Next BVI Inc lent the money to Mart Co and Mart Co lent the same amount of money to PT Indo.

a. What's the term representing the above arrangement? Explain!

b. How much is the potential loss of Indonesia in the event? Assumed, in 2019, PT Indo paid interest to Mart Co of Rp 5.000.000.000 (contribution:10%)

2.XYZ Co (France) assigns its staffs to PT ABC (Indonesia) for 2 years. The employees receive salary directly from PT ABC. In addition to that, XYZ Co provides services that performed in France. XYZ Co receives IDR 500 million from PT ABC.

In relation to the income derived by XYZ Co, which one of the following is true?

a. The income is taxed at 20% from gross revenue.

b. The income is not subject to income tax.

c. The income is subject to tax at 10% on gross revenue according to tax treaty between Indonesia-France

d. The income is subject to tax 0%