INTERNATIONAL TAXATION

1. In January 2019, SS Fund Pte. Ltd Singapore entered into agreement with PT AS to provide long term loan for USD 50.000.000. The Loan bear interest for USD 1.500.000 per annum and due on July every year. SS Fund attached DGT along with the invoice sent to PT AS. Since the answers in Part V of DGT failed to indicate that SS Fund Pte. Ltd Singapore is the beneficial owner of the interest income, what should PT AS do?

a. PT AS shall apply 10% withholding tax art.26 on USD 1.500.000

b. PT AS shall apply 20% withholding tax art.26 on USD 1.500.000

c. PT AS shall apply 10% withholding tax art.26 on USD 750.000

d. PT AS shall apply 20% withholding tax art.26 on USD 750.000

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2. PT GS signed a contract with Singtel Pte, Ltd., Singapore to distribute 100.000 copies of specific design software. Singtel Pte Ltd Singapore made the copy and delivers the software itself. Singtel Pte. Ltd Singapore charged USD 50.000 for the software. What is the tax implication on the payment of the transaction?

a. The payment considered as royalty and the tax charged is USD 7.500

b. The payment considered as royalty and the tax charged is USD 5.000

c. The payment considered as royalty and the tax charged is USD 2.500

d. The payment may not be considered as royalty

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3. Cola Cola is a famous brand in the food and beverage industry in Singapore owned by Cola Cola Pte Ltd. Knowing this, Boy William, an entrepreneur based in Jakarta, decided to buy a license to sell that drink in a major shopping mall in Jakarta. For this, he paid a license fee which is basically calculated as 10% of monthly sales to Cola Cola. As a good citizen, Boy Willliam seeks an advice from you on the tax implications of these payments. Your advice would be:

a. Boy William should withhold 20% as income tax (section 26 of the income tax legislation)

b. Boy William should only withhold 15% as income tax (section 26 of the income tax legislation)

c. Boy William should only withhold 15% as income tax (section 23 of the income tax legislation)

d. This income was derived from outside Singapore and as a result, is exempt under the Singaporean income tax legislation

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4. Ocl Co., a foreign shipping company, has established a representative office in Jakarta to serve its Indonesian customer for internasional sea transportation. Which of the following is the most appropriate tax treatment on income derives by representative office?

a. Net income before income tax, from Indonesian source, shall be subject to income tax rate of 25% and, in addition, branch profit tax of 25% from net income after income tax.

b. Net income before income tax, from Indonesian source, shall be subject to income tax rate of 25%

c. Gross income from Indonesian source shall be subject to income tax rate of 2,64%

d. Net income before income tax, from worldwide sources, shall be subject to income tax rate of 25% and, in addition, branch profit tax of 25% from net income after income tax

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5. Amir is Indonesian tax resident who owns 40% of the share in Singapore Ltd. Under 2019 Singapore Ltds income statement show as following details: Income before tax : SGD 10.000.000 Corporate Income tax : SGD 1.700.000 Income after tax : SGD 8.300.000 Nevertheless, after a quarter of 2020, Amir as a majority shareholder of Singapore Ltd. has no received any deviden payment. Based on the data above

a. In the fourth month after the annual corporate income tax return filling deadline in Singapore, Amir has to declare his dividend income

b. Amir is deemed to received dividend from Singapore Ltd on the amount of SGD 3.320.000

c. Both A and B are correct answers

d. A,B,C are incorrect answers