Help me with those questions please, thankyou so much!

Subject : International Taxation

Question 1, point 40% #Q1.1 PT XTZ signs a secondment agreement with Paris Saint Germany Company (PSG Co.), a company residing in France. PSG assigns its staffs as PT XTZ's employees for 5 months. The employees obtain salaries directly from PT XTZ. In addition to that PSG Co provides advices from France. In relation with the above agreement, PT XTZ pays IDR 500 million to PSG Company, Questions: 1. What is the payment made by PT XTZ to PSG Company called? a. Management fee. b. Technical fee. C. Consultant fee. d. Employment fee. thu nhliation in relation to the payment to PSG Company? b. 2. What is PT XTZ's tax obligation in relation to the payment to PSG Company? a. The said payment is subject to withholding tax at the rate of 20% from gross amount. Withholding tax article 26 at 10%. c. Withholding tax article 26 at 0%. d. Exempted from income tax according to tax treaty between Indonesia-France. #Q1.2 Lyon Construction Company (France) wins a bid for the cable installation under the Java Sea. The Installation started on March 1, 2015 and will be completed on July 31, 2015. The value of the contract Is IDR 10 billion Please answer the following questions: 1.What is the tax position of Lyon Construction Company (LCC)? a. There is a permanent establishment of LCC. b. There is no permanent establishment of LCC. C. There is a representative office of LCC. d. There is no representative office of LCC. 2. The tax treatment on the said income derived by LCC, a. Subject to income tax in Indonesia. b. Exempted from income tax in Indonesia. c. Subject to income tax at the rate of 0,44% of its total export to Indonesia. d. Subject to income tax at the rate of 20% of the gross proceed. #Q1.3 XYZ Co (France) assigns its staffs to PT ABC (Indonesia) for two 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 Problem: In relation to the income derived by XYZ CO, 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% Question 2, point 20% #Q2.1 Define the contracting state in which the taxing right prevails and the Indonesian tax obligation (if any) for the followings (assume that 1 US$= IDR 14.500): Question 2. paint 20% 802.1 Define the contracting state in which the taxing right prevails and the Indonesian tax obligation of any for the followings (assume that 1 USS-IDR 14.500): a) Mr. Jono, an Indonesia resident, is an employee of a SingShip Co, a Singapore ship company which is operated in the international traffic. During his service abourd the ship in the year 2014, he receives total income of USD 36.000 b) In the Year 2019, Port of Singapore Authority provides loan to the government of Indonesia amounting to USD 300.000.000 with interest rate of 15% per year. In the Year 2010, Indonesia paid interest of USD 45.000.000 In providing the answers to the above, discuss the relevant articles in the related Tax Treaty and/or Indonesian Income Tax 10.2.2 Sony corporation, a permanent establishment in Indonesia based in Tokyo in 2019, has a net income before tax of IDR 30,000,000,000. After the income statement is carried out, the fiscal reconciliation has a Net Income before tax of IDR 35,000,000,000. There is no account correction between Sony Corporation and its head office. Calculate the income tax payable! Question 3 point 20% In 2019, BV loc a company incorporated in British Virgin Island, intended to lend some money to its Indonesian subsidiary. PT Indoindo, with fair interest rate. To do, firstly avi Ins created another subsidiary, Mart Co, In Mauritius Next Bloc lent the money to Mart Co and Mart Colent the same amount of money to PT Indoindo a. What's the term representing the above arrangement? Explain it b. How much is the potential loss of Indonesia in the event? Assumed, in 2019, PT lodoindo paid interest to Mart Co of Rp 5.000.000.000 (contribution: 10% Question 4, point 20% Great Corp is a heavy equipment manufacturer in the United States. To market its products in Indonesia, established PT AB with 60% share ownership. Apart from selling Great Corp products, PT AB also sells Good Corp products, an independent company domiciled in Paris. The following is data on the purchase price of the two companies and the selling price to independent consumers in Indonesia for 2019. Units bought & sold Selling price per unit Purchase Price per unit Great Corp Product 100 $ 150,00 $ 135,00 Good Corp Product 50 $ 140,00 $ 119,00 Please explain the transaction above is related to the Transfer Pricing