Indonesia: Amended CFC rules - KPMG Global
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Indonesia: Amended controlled foreign company (CFC) rules

Indonesia: Amended CFC rules

The controlled foreign company (CFC) rules were amended by regulation—No. PMK-107/PMK.03/2017, released in late July 2017 by the Ministry of Finance—effective for fiscal year 2017.


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The main definition of a CFC remains the same—that is, a non-listed foreign company that is at least owned 50% by an Indonesian taxpayer (company or individual) or by a group of Indonesian taxpayers. A change made by the regulation is that the CFC rules now apply with respect to indirectly owned (non-listed) CFCs. This, in turn, may affect the rules that apply for the foreign tax credits available for dividends paid by a CFC.


Read an August 2017 report [PDF 3 MB] prepared by the KPMG member firm in Indonesia

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