The sale or transfer of shares of an intermediary company (special purpose company or conduit company) can be defined as the sale or transfer of shares of an entity established or domiciled in Indonesia, or the sale or transfer of a permanent establishment in Indonesia.
Income from the sale or transfer of shares withholds final Income Tax of 20% (twenty percent) of the estimated net income. The estimated net income is 25% (twenty five percent) of the selling price.
Tax deductions for shares sales made by WPLN can be carried out by two parties. First, tax is withheld by the buyer, as long as the buyer is the party appointed to withhold the tax. For example, Mr. Jason sold shares in PT A to PT B. So, PT B is obliged to withhold Income Tax Article 26.
Second, tax is withheld by the company issuing the shares, in the event that the buyer is a WPLN. For example, F Ltd. transferred its share ownership in PT D to J Co. F Ltd and J Co are WPLN, so PT D is obliged to withhold PPh Article 26.
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