Indirect sale of Indonesian Shares Involving Special Purpose Company

The sales of shares of a conduit company (SPC) owning Indonesian shares located in a tax haven country by a non- Indonesian tax resident can be deemed as a sale of shares of Indonesian party by the non-Indonesian tax resident so long as there is a special relationship between the SPC and the Indonesian party.
Tax haven country is defined as a country that has a corporate tax rate 50% lower than that of Indonesia or a country that does not have a provision of exchange of information with Indonesia.

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