COPY REGULATION OF MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA NUMBER 150 /PMK.010/2018 CONCERNING

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1 MINISTER OF FINANCE REPUBLIC OF INDONESIA COPY REGULATION OF MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA NUMBER 150 /PMK.010/2018 CONCERNING PROVISION OF CORPORATE INCOME TAX DEDUCTION FACILITY BY THE GRACE OF GOD ALMIGHTY THE MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA, Considering : a. that the provisions concerning the provision of Corporate Income Tax deduction facility have been set up in the Regulation of Minister of Finance Number 35/PMK.010/2018 concerning Provision of Corporate Income Tax Deduction Facility; b. that in order to further increase direct investment activities in pioneer industry to boost economic growth and for alignment with the provisions related to business license based on Government -1-

2 Regulation Number 24 of 2018 on Online Single Submission, it is necessary to replace the provision of Corporate Income Tax deduction facility as referred to in paragraph a; c. that based on the considerations as referred to in paragraphs a and b, as well as to implement the provisions of Article 30 of Government Regulation Number 94 of 2010 concerning the Calculation of Taxable Income and Settlement of Withholding Tax in Current Year, it is necessary to establish a Regulation of the Minister of Finance concerning Provision of Corporate Income Tax Deduction Facility; In view of : 1. Law Number 7 of 1983 concerning Withholding Tax (State Gazette of the Republic of Indonesia of 1983 Number 50, Supplement to the State Gazette of the Republic of Indonesia Number 3263) as amended several times, most recently by Law Number 36 of 2008 concerning Fourth Amendment to Law Number 7 of 1983 concerning Withholding Tax (State Gazette of the Republic of Indonesia of 2008 Number 133, Supplement to the State Gazette of the Republic of Indonesia Number -2-

3 4993); 2. Law Number 25 of 2007 concerning Investment (State Gazette of the Republic of Indonesia of 2007 Number 67, Supplement to the State Gazette of the Republic of Indonesia Number 4724); 3. Government Regulation Number 94 of 2010 concerning Calculation of Taxable Income and Settlement of Withholding Tax in Current Year (State Gazette of the Republic of Indonesia of 2010 Number 161, Supplement to the State Gazette of the Republic of Indonesia Number 5183); 4. Government Regulation Number 24 of 2018 concerning Online Single Submission Services (State Gazette of the Republic of Indonesia of 2018 Number 90, Supplement to the State Gazette of the Republic of Indonesia Number 6215); HAS DECIDED: To stipulate : REGULATION OF THE MINISTER OF FINANCE CONCERNING PROVISION OF CORPORATE INCOME TAX DEDUCTION FACILITY. -3-

4 Article 1 In this Regulation any reference to: 1. Pioneer industry is an industry that has extensive connections, gives add value and high externality, introduces new technologies, and has a strategic value for the national economy. 2. Main Business Activity is the business field and the type of production as set out in the principle license, investment license, investment registration, or Taxpayer business license at the time of submission of application for Provision of Corporate Income Tax Deduction Facility, including the expansion and changes to the extent included in the criteria of Pioneer Industry. 3. Commercial Production Commencement is the first time the results of production of Main Business Activity sold to the market and/or used by itself for further production process. 4. Online Single Submission hereinafter abbreviated as OSS is business licensing by OSS Agency for and on behalf of the minister, the head of the institution, governor or regent/mayor to businesses through an integrated electronic system. -4-

5 5. OSS Management and Operator Agency hereinafter referred to as OSS Agency is a non-ministerial government institution organizing government affairs in the field of coordination of investment. Article 2 (1) Corporate Taxpayers making new investments in Pioneer Industry may obtain Corporate Income Tax Deduction on income received or gained from their Main Business Activities. (2) The new capital investment as referred to in paragraph (1) shall at least be Rp ,00 (one hundred billion rupiah). (3) Corporate Income Tax deduction as referred to in paragraph (1) shall be as follows: a. 100% (one hundred percent) of the Corporate Withholding Tax payable for new investments as referred to in paragraph (1) of at least Rp ,00 (five hundred billion rupiah); and b. 50% (fifty percent) of the Corporate Withholding Tax payable for new investments as referred to in paragraph (1) of at least -5-

6 Rp ,00 (one hundred billion rupiah) and maximum less than Rp ,00 (five hundred billion rupiah). (4) The term of Corporate Income Tax deduction as described in paragraph (3) point a shall be given based on the following provisions: a. for five (5) fiscal years for new investment and the planned investment at least Rp ,00 (five hundred billion rupiah) and less than Rp ,00 (one trillion rupiah); b. for 7 (seven) fiscal years for new investment with planned investment of at least Rp (one trillion rupiah) and less than Rp (five trillion rupiah); c. for 10 (ten) fiscal years for new investment with planned investment of at least Rp ,00 (five trillion rupiah) and less than Rp (fifteen trillion rupiah); d. for 15 (fifteen) fiscal years for new investment -6-

7 with planned investment of at least Rp ,00 (fifteen trillion) and less than Rp ,00 (thirty trillion rupiah); e. for 20 (twenty) fiscal years for new investment with planned investment of at least Rp ,00 (thirty trillion rupiah). (5) The term of Corporate Income Tax deduction as described in paragraph (3) point b shall be given for five (5) fiscal years. (6) After the expiry of the term of provision of Corporate Income Tax deduction as referred to in paragraph (4) or paragraph (5), taxpayers shall be given of Corporate Income Tax deduction as follows: a. 50% (fifty percent) of the Corporate Withholding Tax payable for the next two (2) years for new investment as referred to in paragraph (3) point a; or b. 25% (twenty five percent) of the Corporate Withholding Tax payable for the next two (2) years for new investments as referred to in -7-

8 paragraph (3) point b. Article 3 (1) In order to obtain Corporate Income Tax deduction as referred to in Article 2 paragraph (1) corporate Taxpayers must meet the following criteria: a. it is a Pioneer Industry; b. it is an Indonesia's corporation; c. it is a new investment to which it has not been issued a decision on the granting or notification concerning the rejection of Corporate Income Tax deduction; d. it has an investment plan of at least Rp (one hundred billion rupiah); and e. it meets the provision of debt and capital ratio as referred to in the Regulation of Minister of Finance concerning the determination of the company s debt and capital ratio for the purpose of calculating withholding tax. (2) Pioneer Industry as referred to in paragraph (1) a includes: a. upstream base metal industry: 1. steel; or -8-

9 2. non-steel, without or with its integrated derivatives; b. oil and gas refining without or with its integrated derivatives; c. petroleum-based petrochemical industry, natural gas or coal without or with its integrated derivatives; d. organic basic chemicals industry sourced from agriculture, plantation, or forestry without or with its integrated derivatives; e. inorganic basic chemicals industry without or with its integrated derivatives; f. main raw materials of pharmaceutical industry without or with its integrated derivatives; g. Irradiation, electro-medical, or electrotherapy equipment manufacturing industry; h. Electronics or telematics equipment main components manufacturing industry, such as semiconductor wafers, backlight for Liquid Crystal Display (LCD), electrical driver, or the display. i. machinery and machine main components manufacturing industry; -9-

10 j. robotic components manufacturing industry that support manufacturing machine industry; k. power plant machine main components manufacturing industry; l. motor vehicle and motor vehicle main components manufacturing industry; m. vessel main component manufacturing industry; n. train main component manufacturing industry; o. aircraft main component and aerospace industry supporting activities manufacturing industry; p. agriculture, plantation, or forestry producing pulp-based processing industry without or with its derivatives; q. economic infrastructure; or r. digital economy that includes data processing, hosting, and activities associated with it. (3) Details of business sectors and types of production of each Pioneer Industry coverage as referred to in paragraph (2) shall be determined by the Regulation of Investment Coordinating Board, -10-

11 based on the results of coordination meeting organized by the Coordinating Ministry for Economic Affairs. (4) In the event the Taxpayer as referred to in paragraph (1) is directly owned by domestic Taxpayer, in addition to meeting the criteria as referred to in paragraph (1), the Taxpayer must demonstrate that all shareholders recorded in the establishment deed have meet the taxation obligations. (5) In the event of change of shareholders, the taxation obligation compliance requirements as referred to in paragraph (4) shall only apply to shareholders recorded in the most recent amendment deed. (6) Taxation obligation compliance of shareholders as referred to in paragraph (4) or paragraph (5) shall be evidenced by a fiscal certificate. (7) Fiscal certificate as referred to in paragraph (6) shall be issued by the taxation authorities in accordance with the provisions of legislations in the field of taxation. Article 4 (1) The determination of the suitability of the -11-

12 fulfillment of the criteria as referred to in Article 3, paragraph (1) shall be carried out through the OSS system. (2) In the event of new investment, Taxpayer: a. has met the criteria as referred to in Article 3, paragraph (1), the OSS system shall generate notice to the Taxpayer that the investment has met the criteria to obtain Corporate Income Tax deduction facility; b. has not met the criteria as referred in Article 3, paragraph (1), the OSS system shall generate notice to the Taxpayer that the investment has not met the criteria to obtain Corporate Income Tax deduction facility. (3) In the event Taxpayer has received notification as referred to in paragraph (2) point a, the Taxpayer shall be deemed to have applied for Corporate Income Tax deduction if the Taxpayer has submitted formalities as referred to in Article 3 as follows: a. softcopy of details of fixed assets in the investment plan and the debt to equity ratio; and -12-

13 b. softcopy or electronic documents of certificate of fiscal of the shareholders, through OSS system prior to Commercial Production Commencement of the new investments. (4) The application for Corporate Income Tax deduction as referred to in paragraph (3) shall be conducted: a. simultaneously with the registration of the business registration number for new Taxpayer; or b. no later than 1 (one) year from the issuance of business license for the new investment. (5) Application for Corporate Income Tax deduction as referred to in paragraph (3) which has been completely received, shall be delivered by the OSS system to the Minister of Finance through the Director General of Tax as proposal for the granting of Corporate Income Tax deduction, and the OSS system shall serve notification on the Taxpayer that the application for the Corporate Income Tax deduction has been forwarded to the Minister of Finance. -13-

14 Article 5 (1) In the event a Taxpayer applies for Corporate Income Tax deduction for industry coverage not listed in the scope of Pioneer Industry as referred to in Article 3 paragraph (2) and has met the criteria as referred to in Article 3 (1) points b through e, and the requirements in Article 3 paragraph (6), and the Taxpayer in question stated that its industry is a Pioneer Industry, the application shall be discussed among the ministries. (2) The inter-ministerial discussion as referred to in paragraph (1) shall be coordinated by the Investment Coordinating Board to determine the suitability of the business field of the Taxpayer with the criteria of Pioneer Industry, at least involving Ministry of Finance and the ministries/agencies supervising the sector. (3) In the event the inter-ministerial discussion as referred to in paragraph (2) decides that the coverage of industry of the Taxpayer has met the criteria as a Pioneer Industry, the Head of the Investment Coordinating Board may apply for a Corporate Income Tax deduction as referred to in -14-

15 paragraph (1) to the Minister of Finance through the Director General of Tax. (4) The submission of application by the Head of the Investment Coordinating Board as referred to in paragraph (3) shall be conducted through the OSS system. Article 6 (1) The Provision of Corporate Income Tax deduction shall be decided by the Minister of Finance after receiving proposal of Corporate Income Tax deduction as referred to in Article 4 paragraph (5) or Article 5, paragraph (3). (2) The Provision of Corporate Income Tax deduction as referred to in paragraph (1) shall be mandated to the Director General of Taxes for and on behalf of the Minister of Finance. (3) The decision as referred to in paragraph (2) shall be issued not later than 5 (five) working days from the receipt of correct and complete proposal of Corporate Income Tax deduction. (4) Director General of Tax who received the delegation of authority from the Minister of Finance as referred to in paragraph (2): -15-

16 a. shall observe the provisions of legislation; b. shall be substantially responsible for the implementation of the delegation of authority given to the person concerned; and c. shall not sub-delegate the delegation of authority received to other parties. Article 7 (1) Corporate Income Tax Deduction as referred to in Article 2 paragraph (1) shall be effectively used by Taxpayer from the fiscal year of Commercial Production Commencement. (2) The commercial production commencement as referred to in paragraph (1) shall be determined by the Director General of Tax based on the results of field inspection. (3) Field inspections as referred to in paragraph (2) shall be conducted after the Director General of Tax has received notice from the Head of the Investment Coordinating Board concerning the request for the establishment of commercial production commencement from the Taxpayer. (4) Determination as referred to in paragraph (2) shall state: -16-

17 a. Commercial Production Commencement Date; b. realization of new capital investment at the Commercial Production Commencement; and c. conformance between the realization and the plan of Main Business Activity. (5) Further provisions concerning procedures for field inspection as referred to in paragraph (2) shall be provided by the Director General of Tax. Article 8 (1) Taxpayers receiving assignment from the government in accordance with legislation concerning accelerated implementation of national strategic projects may apply for Corporate Income Tax deduction as referred to in Article 2 paragraph (1) to the extent it meets the provisions as referred to in Article 3 and the following conditions apply: a. when applying for Corporate Income Tax deduction it is exempt from the provisions as referred to in Article 4 paragraph (1); b. Corporate Income Tax deduction shall be utilized by the Taxpayers to the extent it has met Commercial Production Commencement and has realized all of its investment plan in -17-

18 accordance with the documents as referred to in Article 4, paragraph (3); c. utilization of Corporate Income Tax deduction as referred to in point b shall be determined by the Director General of Tax based on field inspection; d. field inspection as referred to in point c shall be conducted after the Director General of Tax has received notice from the Head of the Investment Coordinating Board concerning the application for utilization of Corporate Income Tax deduction; and e. determination as referred to in point c shall at least consists of: 1. Commercial Production Commencement date and realization of the entire new investment plan; 2. Total new capital investment realization; and 3. Conformity between the realization and the plan of Main Business Activity. (2) Government assignment as referred to in paragraph (1) is an assignment set by a decree of -18-

19 minister or ministerial-level institutional head. (3) Further provisions on procedures for field inspection in the establishment of the utilization of Corporate Income Tax deduction as referred to in paragraph (1) point c shall be provided by the Director General of Tax. Article 9 In the event based on the field inspection as referred to in Article 7 (2) and Article 8, paragraph (1) point c it is found that: a. the total realization of new investment plan of the Taxpayer is less than the minimum limit for new investment plan underlying the period of Corporate Income Tax deduction as referred to in Article 2 (4); b. the total realization of new investment of the Taxpayer is more than or equal to Rp (one hundred billion rupiah); and c. there is conformance between the realization and the plan of Main Business Activity. the amount and/or term of Corporate Income Tax deduction as stated in the decision as referred to in -19-

20 Article 6 paragraph (1) shall be adjusted to the amount of Corporate Income Tax deduction hat should have been obtained by Taxpayers as referred to in Article 2 paragraph (3) and/or the term of Corporate Income Tax deduction that should have been obtained by Taxpayers as defined in Article 2 (4) or paragraph (5). Article 10 (1) Taxpayers who have obtained Decree of the Minister of Finance concerning the provision of Corporate Income Tax deduction shall submit on annual basis to the Director General of Tax and Head of Fiscal Policy Agency in the form of: a. report on the realization of investment as of receiving Decree of Minister of Finance concerning the provision of Corporate Income Tax deduction until Commercial Production Commencement or until the investment plan has been realized for Taxpayers receiving government assignment in accordance with the legislations concerning accelerated implementation of national strategic projects; and b. report on realization of production as of the -20-

21 fiscal year of the Commercial Production Commencement until the expiry of the term of utilization of Corporate Income Tax deduction or from the fiscal year of determination of Corporate Income Tax deduction until term the expiry of term of utilization of Corporate Income Tax deduction for Taxpayers receiving government assignment in accordance with legislations concerning accelerated implementation of national strategic projects. (2) Reports as referred to in paragraph (1) shall be submitted within 30 (thirty) days from the end of the fiscal year in question. (3) Further provisions concerning reporting procedures as referred to in paragraph (1) shall be provided by the Director General of Tax. Article 11 (1) The decision as referred to in Article 6 paragraph (1) shall be revoked, in the event: a. based on the results of field inspection as referred to in Article 7 paragraph (2) or Article 8 (1) c, it is found the total realization of new -21-

22 investment of Taxpayer is less than Rp (one hundred billion rupiah); b. based on the results of field inspection as referred to in Article 7 paragraph (2) or Article 8 (1) c, it is found discrepancy between the realization and the Main Business Activity plan; c. Taxpayers import, purchase, or acquire used capital goods in the realization of the new investment that obtains the Corporate Income Tax deduction, unless the used capital goods in question are relocating as a whole as a package of new investments from other countries and are not produced in the country and/or Taxpayer who gets the assignment government according to laws and regulations concerning accelerated implementation of the national strategic project; d. Taxpayers realize Main Business Activity that is not in accordance with the Main Business Activity plan during the term of utilization of Corporate Income Tax deduction; -22-

23 e. Taxpayers transfer its assets during the term of utilization of Corporate Income Tax deduction, unless the transfer is done for the purpose of increasing efficiency and does not cause realization of new investment that less than the new investment plan; and/or f. Taxpayers relocate new investment abroad. (2) Revocation of decree as a result of the case referred to in paragraph (1) points a and b shall be decided by the Director General of Tax on behalf of the Minister of Finance. (3) Revocation of decree as a result of the case as referred to in paragraph (1) points c through f shall be determined by the Director General of Tax on behalf of the Minister of Finance after obtaining recommendation of the Head of the Fiscal Policy Agency. (4) Taxpayers who are subject to revocation as referred to in paragraph (3) shall return the Corporate Income Tax deduction that has been used and be sanctioned in accordance with the provisions of legislation in the field of taxation, and longer eligible for Corporate Income Tax deduction. -23-

24 (5) Further provisions concerning the procedures for revocation of decree on Corporate Income Tax deduction as described in paragraph (2) and (3) shall be regulated by the Director General of Tax. Article 12 (1) Taxpayers who obtain the Corporate Income Tax deduction as referred to in Article 2 shall: a. maintain separate books on incomes obtaining the Corporate Income Tax deduction and other incomes that do not obtain Corporate Income Tax deduction; and b. continue to implement the withholding and assessment of tax liabilities to the other party in accordance with the provisions of legislation in the field of taxation. (2) In the event of shared cost for Taxpayers as described in paragraph (1) point a that cannot be separated in order to calculate the amount of taxable income, it shall be allocated proportionally. (3) Incomes received and earned by Taxpayers from Main Business Activities shall not be withheld and assessed during the term of utilization of Corporate Income Tax deduction without issuing issuance of -24-

25 certificate of exemption. (4) Incomes received and earned by Taxpayers from outside the Main Business Activities shall remain be withheld and assessed in accordance with the provisions of the legislations in the field of Withholding Tax. Article 13 Director General of Tax shall submit quarterly reports to the Minister of Finance on the implementation of the provision of Corporate Income Tax deduction facility. Article 14 Corporate Income Tax deduction facility as referred to in the provisions of this Regulation shall be published and evaluated on regular basis. Article 15 (1) New investments as referred to in Article 2 paragraph (1) which has obtained the Decree of the Minister of Finance concerning Corporate Income Tax deduction hereunder shall not be given Withholding Tax facility for investments in certain business fields and/or in specific areas as referred to in Government Regulation concerning -25-

26 Withholding Tax facilities for investments in certain sectors and/or in specific area. (2) New investment that has not yet obtained the Decree of Minister of Finance concerning Corporate Income Tax deduction hereunder may be granted Withholding Tax facilities for investments in certain business fields and/or specific areas as referred to in the Regulation of Government concerning Withholding Tax facilities for investments in certain business fields and/or specific area. (3) The provisions as referred to in paragraph (1) and (2) also apply to: a. Taxpayers who obtain exemption or deduction facilities of Corporate Income Tax under the Regulation of Minister of Finance Number 130/PMK.011/2011 on Provision of Exemption or deduction facilities of Corporate Income Tax, as amended by Regulation of the Minister of Finance Number 192/PMK.011/2014 on Amendments to Regulation of the Minister of Finance Number 130/PMK.011/2011 on Provision of Exemption or deduction facilities of Corporate Income Tax; -26-

27 b. Taxpayers who obtain Corporate Income Tax deduction facility under Regulation of Minister of Finance Number 159/PMK.010/2015 concerning Provision of Corporate Income Tax Deduction Facility, as amended by Regulation of the Minister of Finance Number 103/PMK.010/2016 on Amendments to the Regulation of Minister of Finance Number 159/PMK.010/2015 on Provision of Corporate Income Tax Deduction Facility; or c. Taxpayers who obtain Corporate Income Tax deduction facility under Regulation of Finance Minister Number 35/PMK.010/2018 concerning Provision of Corporate Income Tax Deduction Facility. Article 16 Corporate Income Tax Deduction Facility hereunder shall be given based on: a. proposals submitted to the Minister of Finance as referred to in Article 4 paragraph (5); or b. application for tax reduction as referred to in Article 5 paragraph (3), delivered in a period of at least five (5) years from the -27-

28 entry into force of this regulation. Article 17 Upon enactment hereof: 1. Taxpayers who have obtained and/or utilized exemption or deduction facilities of Corporate Income Tax under Regulation of Minister of Finance Number 130/PMK.011/2011 on Provision of Exemption or Deduction Facilities of Corporate Income Tax, as amended by Regulation of the Minister of Finance Number 192/PMK.011/2014 on Amendments to the Regulation of the Minister of Finance Number 130/PMK.011/2011 on Provision of Exemption or Deduction Facilities of Corporate Income Tax may still utilize the exemption or deduction facilities of Corporate Income Tax until the expiration of the utilization of the exemption or deduction facilities of Corporate Income Tax in question. 2. Taxpayers who have obtained and/or utilized Corporate Income Tax deduction facility under Regulation of the Minister of Finance Number 159/PMK.010/2015 on Provision of Corporate Income Tax Deduction Facility as amended by -28-

29 Regulation of the Minister of Finance Number 103/PMK.010/2016 concerning Amendments to the Regulation of the Minister of Finance Number 159/PMK.010/2015 concerning Provision of Corporate Income Tax Deduction Facility, may still utilize the Corporate Income Tax deduction facility until the expiration of the utilization of the Corporate Income Tax deduction facility in question. 3. Corporate Taxpayers who have obtained and/or utilized Corporate Income Tax deduction facility under Regulation of the Minister of Finance Number 35/PMK.010/2018 concerning Provision of Corporate Income Tax Deduction Facility, may still utilize the Corporate Income Tax deduction facility until the expiration of the utilization of Corporate Income Tax deduction facility in question. 4. Proposal for provision of Corporate Income Tax deduction submitted by the Head of Investment Coordinating Board to the Minister of Finance from the date of 4 April 2018 until before the entry into force of this regulation, to which Decree of Minister of Finance concerning provision of Corporate Income Tax deduction has not been issued or -29-

30 otherwise be given written notice of rejection, shall be processed by Regulation of Minister of Finance Number 35/PMK.010/2018 on Provision of Corporate Income Tax Deduction Facility. 5. Taxpayers who have obtained principle license, investment permit, investment registration, or business license issued by the Investment Coordinating Board maximum from the enactment of the Regulation Minister of Finance Number 159/PMK.010/2015 concerning Provision of Corporate Income Tax Deduction Facility, as amended by Regulation of Minister of Finance Number 103/PMK.010/2016 on Amendments to the Regulation Minister of Finance Number 159/PMK. 010/2015 on Provision of Corporate Income Tax Deduction Facility until before the enactment hereof may submit application for Corporate Income Tax deduction to the Head of the Investment Coordinating Board under this regulation unless the fulfillment of pioneer industry coverage as referred to in Article 3 (2) follow the provisions in the Regulation of Minister of Finance Number 35/PMK.010/2018 concerning Provision of -30-

31 Corporate Income Tax Deduction Facility. 6. Procedures for applying for provision of Corporate Income Tax deduction under proposal for provision of Corporate Income Tax deduction as referred to in number 4 and number 5 shall be carried out in accordance with Regulation of Investment Coordinating Board concerning guidelines and procedures for licensing and investment facilities. 7. The provisions as referred to in Article 9 shall also apply to Taxpayers who obtain Corporate Income Tax deduction under Regulation of Minister of Finance Number 35/PMK.010/2018 concerning Provision of Corporate Income Tax Deduction Facility. Article 18 Upon enactment hereof, the Regulation of Minister of Finance Number 35/PMK.010/2018 on Provision of Corporate Income Tax Deduction Facility (State Gazette of the Republic of Indonesia of 2018 Number 451) is revoked and held null and void. Article 19 This Regulation shall come into force on the date of promulgation. -31-

32 For public cognizance, it is ordered the promulgation of this Regulation of Minister by publishing it a State Gazette of the Republic of Indonesia. Stipulated in Jakarta on 26 November 2018 MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA, Signed. SRI MULYANI INDRAWATI Promulgated in Jakarta on 27 November 2018 DIRECTOR GENERAL OF LEGISLATION REGULATION OF MINISTRY OF LAW AND HUMAN RIGHTS OF THE REPUBLIC OF INDONESIA, Signed. WIDODO EKATJAHJANA STATE GAZETTE OF THE REPUBLIC OF INDONESIA OF 2018 NUMBER 1553 True copy Head of General Bureau by Head of Ministry Administration Signed & stamped ARIF BINTATRTO YUWONO EIN AFFIDAVIT I am fluent in both the English Language and the Indonesian Language, hereby declare that the above-mentioned translation is a true and correct translation of the document included above into the English Language. Jakarta, 6th December Drs. Sularno Popomaruto Sworn Translator by virtue SK.Gub.KDKI Jkt.No.1715/2000

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