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HMRC internal manual

Double Taxation Relief Manual

Indonesia: Credit

Admissible for credit under the agreement

Income tax (pajak penghasilan), including company tax (pajak perseroan); also, when applied to income from construction and consultancy service undertakings under Decree 704/KMK.04/1996.

(Withholding) tax on interest, dividends and royalties (pajak atas bunga dividen dan royalty).


Foreigners’ tax (pajak bangsa asing-PBA).

Capital tax (pajak kekayaan). Surcharge for the relief of poverty (Presidential Decrees No.90 of 1995 and No. 92 of 1996).

Any claim to relief for Indonesian capital tax as an expense in computing a United Kingdom chargeable gain should also be refused. Cases of difficulty, including cases where the claimant persists in his claim to relief, should be submitted to HMRC, Business International, Tax Treaty Team.