SURAT DIRJEN PAJAK
S-408/PJ.341/2006
Ditetapkan tanggal 24 Mei 2006

INDONESIA - AUSTRALIA DOUBLE TAX AGREEMENT MUTUAL AGREEMENT PROCEDURE

In response to your letter dated 3 April 2006 concerning the above mentioned subject, I would like to advise you the followings :

1. We thank you for providing us with information and related documents showing that the beneficial owners of the income, which in this case Mr. and Mrs. Dyke, have already reported the income derived from Indonesia through WDF Services and its related taxes.

2. We kindly request your assistance to inform Mr. and Mrs. Dyke about the refund procedures of withholding tax according to our Circular number SE-09/PJ.1/1994, as follows :

   1. A written refund application should be submitted by WDF Services of its authorized person (usually the withholder) to the Head of Tax Office in which the withholder (PT. Porter Rekayasa Utama) is registered accompanied with bank account number to which the refund will be transferred.

   2. Refund application should be accompanied by the following documents :

      • A letter signed by Australian Competent Authority to certify that WDF Services is resident of Australia at the time the it received income from PT. Porter Rekayasa Utama;

      • Power of Attorney (if the refund application is taken care by the authorized person);

      • Withholding slip issued by the withholder (PT. Porter Rekayasa Utama);

      • Other relevant documents (for example : service contract/agreement, etc.)

Sincerely yours,

Sgd.

Herry Sumardjito
Director for Tax Regulations
Competent Authority