PROCEDURES FOR THE MANAGEMENT OF COUNTRY-TO- COUNTRY REPORTS DIRECTOR GENERAL OF TAX,

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1 Type: By: Number: Date: Title: REGULATION (PER) DIRECTOR GENERAL OF TAX (DIRGENTAX) 29/PJ/2017 DECEMBER 29, 2017 (JAKARTA) PROCEDURES FOR THE MANAGEMENT OF COUNTRY-TO- COUNTRY REPORTS DIRECTOR GENERAL OF TAX, Considering: In view of: To stipulate: whereas to implement the provisions of Article 12 paragraph (2) of Regulation of the Minister of Finance Number 213/PMK.03/2016 regarding Types of Additional Documents and/or Information that are Mandatory to be Kept by Taxpayers Conducting Transactions with the Parties Having Special Relationship, and the Management Procedures Thereof, it is necessary to stipulate Regulation of the Director General of Tax regarding Procedures for the Management of Country-to-Country Reports; Regulation of the Minister of Finance Number 213/PMK.03/2016 regarding Types of Additional Documents and/or Information that are Mandatory to be Kept by Taxpayers Conducting Transactions with the Parties Having Special Relationship, and the Management Procedures Thereof (Official Gazette of the Republic of Indonesia Year 2016 Number 2120); HAS DECIDED: REGULATION OF THE DIRECTOR GENERAL OF TAX REGARDING PROCEDURES FOR THE MANAGEMENT OF COUNTRY-TO-COUNTRY REPORTS. Article 1 In this Regulation of the Director General, referred to as: 1. Regulation of the Minister shall be Regulation of the Minister of Finance Number 213/PMK.03/2016 regarding Types of Additional Documents and/or Information that are Mandatory to be Kept by Taxpayers Conducting Transactions with the Parties Having Special Relationship, and the Management Procedures Thereof as well as the amendment(s) thereto. 2. Transfer Price Determination Documents in the form of Country-to-Country Reports, hereinafter referred to as Country-to-Country Reports, shall be Country-to-Country Reports that are delivered every year by Taxpayers based on Regulation of the Minister in the context of implementation of provisions of laws and regulations in the field of taxation and implementation of international agreement in the field of taxation.

2 3. Business Group shall be a group of tax subjects conducting business activities that consist of the parties having Special Relationship. 4. Multinational Business Group shall be Business Group in which the members are domiciled in more than one country or tax jurisdiction. 5. Parent Entity shall be one of the members of Business Group that meets the following criteria: a. directly or indirectly controlling one or more other members in the Business Group; and b. having the obligation to organize consolidated Financial Statement based on the financial accounting standards applicable in Indonesia and/or based on the provisions that bind the issuers of stock exchanges in Indonesia. 6. Constituent Entity shall be Parent Entity and member of the Business Group that are covered in the Country-to-Country Reports as intended in this Regulation of the Director General. 7. International Agreement shall be bilateral or multilateral agreement, which among others states that the Government of Indonesia has bound itself with Partner Country or Partner Jurisdiction, regulating the exchange of information regarding matters related to taxation, among others: a. Agreement on Avoidance of Double Taxation (P3B); b. Tax Information Exchange Agreement; or c. Convention on Mutual Administrative Assistance in Tax Matters. 8. Partner Country or Partner Jurisdiction shall be country or jurisdiction bound to the Government of Indonesia in the International Agreement. 9. Qualifying Competent Authority Agreement, hereinafter referred to as QCAA, shall be agreement between the competent authority of the Government of Indonesia and the competent authority of Partner Country or Partner Jurisdiction that requires the binding parties to inter-exchange the Country-to- Country Reports automatically. 10. DJP Online shall be online tax services provided by the Directorate General of Tax on the website of the Directorate General of Taxation. 11. Notification shall be notice delivered by Taxpayers to the Directorate General of Tax that states the Taxpayers have the obligation or do not have the obligation to deliver Country-to-Country Reports. (1) Resident Taxpayer: Article 2 a. that constitutes the Parent Entity of a Business Group having consolidated gross turnover in the corresponding Fiscal Year of at least

3 Rp ,00 (eleven trillion rupiah) shall be obligated to organize, keep, and deliver Country-to-Country Reports; or b. that constitutes the Constituent Entity the Parent Entity of which constitutes foreign tax subject shall be obligated to deliver Country-to- Country Reports, insofar as the country or jurisdiction where the Parent Entity is domiciled: 1) does not require the delivery of Country-to-Country Reports; 2) does not have any agreement with the Government of Indonesia regarding tax information exchange; or 3) has an agreement with the Government of Indonesia regarding tax information exchange, however, the Country-to-Country Reports cannot be obtained by the Government of Indonesia from the aforementioned country or jurisdiction. (2) Country-to-Country Reports as intended in paragraph (1), must be available a maximum of 12 (twelve) months after the end of Fiscal Year. (3) Parent Entity as intended in paragraph (1) sub-paragraph a shall constitute Parent Entity that: a. is not owned directly or indirectly by other Constituent Entity in the Business Group; or b. is owned directly or indirectly by other entity, however, the other entity is not required to consolidate the Financial Statement of the Parent Entity. (4) Resident Taxpayer as intended in paragraph (1) sub-paragraph a shall not be allowed to appoint another Constituent Entity to replace it in complying with the obligation of delivery of Country-to-Country Reports, whether in Indonesia as well as in other country or jurisdiction. (5) In the event that Parent Entity that constitutes foreign tax subject has appointed Constituent Entity overseas as the substitute of Parent Entity, Resident Taxpayer as intended in paragraph (1) sub-paragraph b shall not be required to deliver Country-to-Country Reports insofar as complying with the following conditions: a. Resident Taxpayer delivers notification regarding the Constituent Entity that is appointed as substitute of the Parent Entity to the Director General of Taxation; and b. country or jurisdiction where the Constituent Entity that is appointed as substitute of the Parent Entity is domiciled: 1) requires the delivery of Country-to-Country Reports; and 2) has QCAA and the Country-to-Country Reports can be obtained by the Government of Indonesia from the concerned Partner Country or Partner Jurisdiction.

4 (6) Constituent Entity that is appointed as substitute of the Parent Entity as intended in paragraph (5) shall be the only Constituent Entity that is appointed as substitute of the Parent Entity in delivering the Country-to-Country Reports to the tax authority in the country or jurisdiction where the concerned Constituent Entity that is appointed is domiciled. (7) In the event that there is more than one Resident Taxpayer that constitutes the Constituent Entity as intended in paragraph (1) sub-paragraph b, Parent Entity that constitutes foreign tax subject can appoint one of the Constituent Entities constituting Resident Taxpayer to deliver Country-to-Country Reports to the Directorate General of Taxation. Article 3 (1) Parent Entity that constitutes foreign tax subject as intended in Article 2 paragraph (1) sub-paragraph b shall be entity that: a. owns directly or indirectly one or more other Constituent Entity in Multinational Business Group; b. has the obligation to organize consolidated Financial Statement based on financial accounting standards or provisions applicable in the country or jurisdiction where the concerned entity is domiciled; c. is not owned directly or indirectly by other Constituent Entity in Multinational Business Group, or is owned directly or indirectly by other entity, however, the other entity is not required to consolidate the Financial Statement of the concerned entity; and d. has consolidated gross turnover in the corresponding Fiscal Year of at least: 1) equal to 750,000, (seven hundred fifty million euro) based on the functional currency exchange rate of Parent Entity in 1 January 2015 in the event that the country or jurisdiction where the concerned Parent Entity is domiciled does not require the delivery of Country-to-Country Reports; or 2) amounting to the limit of consolidated gross turnover constituting the basis for determination of obligation of delivery of Country-to- Country Reports as stipulated in the country or jurisdiction where the concerned Parent Entity is domiciled. (2) Constituent Entity as intended in Article 2 paragraph (1) sub-paragraph b shall constitute: a. every separate business entity that constitutes a member of Multinational Business Group and included in the consolidated Financial Statement of Parent Entity for the purpose of Financial Reporting; b. every business entity that constitutes a member of Multinational Business Group and not included in the consolidated Financial Statement solely due to the consideration of business size or materiality; and/or

5 c. every Permanent Establishment of business entity as intended in subparagraph a or sub-paragraph b insofar as the Permanent Establishment has a separate Financial Statement for the purpose of Financial Reporting, implementation of provisions of laws and regulations, tax reporting, or for the purpose of control of the company s management. (3) Country or jurisdiction where the Parent Entity is domiciled that does not have any agreement with the Government of Indonesia regarding tax information exchange as intended in Article 2 paragraph (1) sub-paragraph b point 2 shall be the country or jurisdiction where the Parent Entity is domiciled that has International Agreement with the Government of Indonesia but does not have QCAA. (4) Country-to-Country Reports cannot be obtained as intended in Article 2 paragraph (1) sub-paragraph b point 3 shall be Country-to-Country Reports that cannot be obtained by automatic information exchange due to the following conditions: a. there is postponement of automatic exchange of Country-to-Country Reports due to the matters other than those stipulated in QCAA; or b. there is repetitive failure in the exchange of Country-to-Country Reports automatically with Partner Country or Partner Jurisdiction. (5) In the event that there is the condition as intended in paragraph (4), Taxpayer as intended in Article 2 paragraph (1) sub-paragraph b must deliver Country-to- Country Reports within 3 (three) months after the announcement of list of Partner Countries or Partner Jurisdictions in which the Country-to-Country Reports cannot be obtained. (6) In the event that the Country-to-Country Reports is not delivered within 3 (three) months as intended in paragraph (5), the Director General of Taxation through the Director of International Taxation shall be authorized to request the Taxpayer as intended in Article 2 paragraph (1) sub-paragraph b to deliver Country-to-Country Reports, by using the format of letter of request as indicated in Attachment letter A that constitutes an inseparable part of this Regulation of the Director General. Article 4 (1) Corporate Taxpayer that constitutes a Constituent Entity or has affiliated transactions must deliver Notification to the Directorate General of Taxation. (2) In the event that Taxpayer as intended in paragraph (1) has the obligation of delivering Country-to-Country Reports as intended in Article 2 paragraph (1), the concerned Taxpayer must deliver Country-to-Country Report that is enclosed with Country-to-Country Report work sheet at the same time as the delivery of Notification. (3) The delivery of Notification as intended in paragraph (1) and delivery of Country-to-Country Reports as intended in paragraph (2) must be made to the Directorate General of Taxation by no later than: a. 16 (sixteen) months after the end of Fiscal Year for Fiscal Year 2016; or

6 b. 12 (twelve) months after the end of Fiscal Year for Fiscal Year 2017 and so on; through DJP Online or manually in the event that DJP Online cannot be used. (4) With regard to the delivery of Notification as intended in paragraph (1) and delivery of Country-to-Country Reports as intended in paragraph (2), receipt shall be given. (5) Receipt for the delivery of Country-to-Country Reports as intended in paragraph (4) can be used as substitute of Country-to-Country Reports, which must be enclosed in the Annual Corporate Income Tax Return as stipulated in Regulation of the Minister. (6) Taxpayer that has delivered the Country-to-Country Reports as intended in paragraph (2) can deliver correction of Country-to-Country Reports concerned by re-delivering the Country-to-Country Reports that has been corrected and enclosed with Country-to-Country Reports work sheet through DJP Online or manually in the event that DJP Online cannot be used. Article 5 (1) Notification shall contain statement regarding: a. identification of Resident Taxpayer that constitutes Parent Entity; b. identification of Resident Taxpayer that does not constitute Parent Entity; and c. statement of obligation of delivery of Country-to-Country Reports. (2) Notification shall be drawn up by filling the form in accordance with the format as indicated in Attachment letter B that constitutes an inseparable part of this Regulation of the Director General. Article 6 (1) Country-to-Country Reports that is delivered by: a. Resident Taxpayer as intended in Article 2 paragraph (1) sub-paragraph a shall be obligated to be organized based on data and information available up to the end of Fiscal Year of the concerned Taxpayer; or b. Resident Taxpayer as intended in Article 2 paragraph (1) sub-paragraph b shall be organized based on data and information available up to the end of Fiscal Year of Parent Entity that constitutes foreign tax subject. (2) Country-to-Country Reports as intended in paragraph (1) must be organized by the production of Country-to-Country Reports work sheet, in the form of digital copy (softcopy) with extension of Extensible Markup Language (XML). (3) In the event that Taxpayer has the obligation as intended in Article 2 paragraph (1) sub-paragraph b, the concerned Taxpayer shall not be required to produce Country-to-Country Reports work sheet as intended in paragraph (2).

7 Article 7 (1) The Director General of Tax shall perform automatic exchange of Country-to- Country Reports with Partner Country or Partner Jurisdiction having QCAA. (2) Implementation of exchange of Country-to-Country Reports as intended in paragraph (1) shall be performed by the Director of International Taxation. Article 8 In the framework of implementation of obligation of delivery of Country-to-Country Reports as intended in Article 2 paragraph (1) sub-paragraph b, the Director General of Tax shall announce the list of Partner Countries or Partner Jurisdictions having: a. International Agreement; b. QCAA; and c. QCAA but the Country-to-Country Reports cannot be obtained as intended in Article 3 paragraph (4), in the official website of the Directorate General of Tax at the end of every year or every occurrence of change of list of Partner Countries or Partner Jurisdictions as intended in sub-article a, sub-article b, and sub-article c. Article 9 The obligation of delivery of Country-to-Country Reports as intended in Article 2 paragraph (1) shall be determined based on Fiscal Year of Parent Entity starting from Fiscal Year Article 10 This Regulation of the Director General shall come into effect as from the date of its stipulation. Stipulated in Jakarta on 29 December 2017 THE DIRECTOR GENERAL OF TAXATION, sgd. ROBERT PAKPAHAN Issued as a true copy SECRETARY OF THE DIRECTORATE GENERAL OF TAXATION on behalf of HEAD OF ORGANIZATION AND MANAGEMENT DIVISION sgd ODING RIFALDI Civil Service Reg. No. (NIP)

8 Note ATTACHMENT REGULATION OF THE DIRECTOR GENERAL OF TAX NUMBER 29/PJ/2017 REGARDING PROCEDURES FOR THE MANAGEMENT OF COUNTRY-TO-COUNTRY REPORTS A. FORMAT OF LETTER OF REQUEST FOR COUNTRY-TO-COUNTRY REPORTS KEMENTERIAN KEUANGAN REPUBLIK INDONESIA DIREKTORAT JENDERAL PAJAK DIREKTORAT PERPAJAKAN INTERNASIONAL JALAN JENDERAL GATOT SUBROTO NOMOR JAKARTA TELEPON (021) , FAKSIMILE (021) ; SITUS LAYANAN INFORMATION DAN PENGADUAN KRING PAJAK (021) ; Number : S-...(1)...(2) Type : Very Urgent Subject : Request for Delivery of Country-to-Country Reports To...(3) NPWP...(4) Address...(5) With reference to the effectiveness of laws and regulations related to the organization, storage and delivery of Country-to-Country Reports, we hereby convey several matters as follows: 1. based on Article 3 paragraph (5) of Regulation of the Director General of Taxation Number 29/PJ/2017 regarding Procedures for the Management of Country-to-Country Reports (PER-29), it is stipulated that in the event that the Country-to-Country Reports cannot be obtained through the exchange of Country-to-Country Reports with Partner Country or Partner Jurisdiction, Taxpayer that constitutes Constituent Entity must deliver Country-to-Country Reports within 3 (three) months after the announcement of list of Partner Countries or Partner Jurisdictions in which the Country-to-Country Reports cannot be obtained; 2. on the date... (6), the Directorate General of Taxation has announced the list of Partner Countries or Partner Jurisdictions in which the Country-to-Country Reports cannot be obtained; 3. based on the Notification on the Country-to-Country Reports that you have delivered, you state that your Parent Entity is domiciled in... (7) that constitutes one of the countries or jurisdictions in which the Country-to-Country Reports cannot be obtained; 4. based on the above matters, and considering that you have not delivered the Country-to-Country Reports up to 3 (three) months after the announcement of list of countries as intended in item 2, hereby you are requested to deliver the Country-to-Country Reports through DJP Online or manually in the event that DJP Online cannot be used, by no later than 30 (thirty) days as from the date of this letter. Please be informed accordingly, thank you for your attention and cooperation.

9 The Director of International Taxation,...(8) GUIDELINES FOR FILLING OUT LETTER OF REQUEST FOR COUNTRY-TO- COUNTRY REPORTS Number. (1) : please fill out with number of letter of request for Country-to- Country Reports from the Directorate of International Taxation. Number (2) : please fill out with the date of letter of request for Country-to- Country Reports. Number (3) : please fill out with Name of Taxpayer. Number (4) : please fill out with Taxpayer Registration Number (NPWP). Number (5) : please fill out with address of Taxpayer. Number (6) : please fill out with the date of announcement of list of Partner Country or Partner Jurisdiction having Qualifying Competent Authority Agreement but the Country-to-Country Reports cannot be obtained. Number (7) : please fill out with name of country or jurisdiction where the Parent Entity is domiciled. Number (8) : please fill out with Name, NIP and signature of the Director of International Taxation. Number (9) : please fill out with name of position that is given carbon copy. B. FORMAT OF NOTIFICATION ON COUNTRY-TO-COUNTRY REPORTS

10 GUIDELINES FOR FILLING OUT NOTIFICATION ON COUNTRY-TO-COUNTRY REPORTS

11 Notification shall be notice that is delivered by Taxpayer to the Directorate General of Taxation stating that Taxpayer has the obligation or does not have the obligation to deliver Country-to-Country Reports. Notification must be delivered by every Corporate Taxpayer that constitutes Constituent Entity or having affiliated transactions. Notification must be delivered to the Directorate General of Taxation by no later than: a. 16 (sixteen) months after the end of Fiscal Year for Fiscal Year 2016; or b. 12 (twelve) months after the end of Fiscal Year for Fiscal Year 2017 and so on; through DJP Online or manually in the event that DJP Online cannot be used. Notification that has been delivered through DJP Online shall not necessarily be printed nor delivered to the Tax Service Office where the Taxpayer is registered. Notification that has been delivered manually (in the event that DJP Online cannot be used) shall be performed by printing out this Notification form, filling it out, and delivering it to the Tax Service Office where the Taxpayer is registered. The delivery of Notification whether through DJP Online or manually will be given a receipt. In printing out the Notification form, it is necessary to take into account the following matters: 1. Please make a (black square) mark in the four corners as document borders so that the document can be scanned; 2. Paper size used is F4 / Legal (8.5 x 13 inch) with minimum weight of 70 gram; and 3. Paper cannot be folded or twisted. FISCAL YEAR Please fill out with figure of Fiscal Year of Country-to-Country Reports in the existing box Example: Notification for Country-to-Country Reports of Fiscal Year 2016 PERIOD OF BOOKKEEPING Please fill out with figure of month and year of commencement of bookkeeping up to the end of month and year of bookkeeping reported in the Country-to-Country Reports. Example: Period of bookkeeping 1 April 2016 up to 31 March 2017 to IDENTITY Name of Taxpayer : filled out in accordance with the name indicated in NPWP card. NPWP : filled out in accordance with NPWP indicated in NPWP card. PART I. IDENTIFICATION OF RESIDENT TAXPAYER THAT CONSTITUTES PARENT ENTITY

12 Taxpayer that fills out Part I shall be every Resident Taxpayer that constitutes Parent Entity of a Business Group, namely one of the members of Business Group that constitutes Resident Taxpayer: a. controlling directly or indirectly one or more other member in the Business Group; and b. having the obligation to organize consolidated Financial Statement based on financial accounting standards applicable in Indonesia and/or based on the provisions binding the issuer of stock exchange in Indonesia. Statement A-1 up to A-4 must be filled out by giving checkmark ( ) in each box in accordance with the condition of Taxpayer (can be given checkmark in more than one box), on the condition that: 1. statement A-1 is given checkmark in the event that Taxpayer controls directly or indirectly one or more other members in the Business Group. 2. statement A-2 is given checkmark in the event that Taxpayer is obligated to organize consolidated Financial Statement based on financial accounting standards applicable in Indonesia and/or based on the provisions binding the issuer of stock exchange in Indonesia. 3. statement A-3 is given checkmark in the event that Taxpayer is not owned directly or indirectly by other Constituent Entity, or owned directly or indirectly by other entity, however, the other entity is not obligated to consolidate the Financial Statement of Taxpayer. 4. statement A-4 is given checkmark in the event that Taxpayer has consolidated gross turnover in the corresponding Fiscal Year of more than or equal to Rp ,00 (eleven trillion rupiah). Every Resident Taxpayer that puts a checkmark in statement A-2 and/or A-4, must fill out statement B by indicating the value of consolidated gross turnover Taxpayer in rupiah currency based on the consolidated Financial Statement. In the event that Taxpayer has obtained permit of the Minister of Finance to organize bookkeeping using foreign language and currency other than rupiah, the value of consolidated gross turnover of Taxpayer in rupiah currency shall be equal to the value of currency other than rupiah based on the exchange rate stipulated by the Minister of Finance for the calculation of tax at the end of Fiscal Year. Number (1) : please fill out with value of consolidated gross turnover of Taxpayer for the corresponding Fiscal Year based on the consolidated Financial Statement. PART II. IDENTIFICATION OF RESIDENT TAXPAYER THAT DOES NOT CONSTITUTE PARENT ENTITY Taxpayer that fills out Part II shall be every Resident Taxpayer (including Permanent Establishment/BUT), which: a. does not constitute Parent Entity of a Business Group; or b. constitutes Parent Entity of a Business Group, however: 1. it is owned directly or indirectly by other Constituent Entity in the same Business Group; or

13 2. there is another Constituent Entity in the same Business Group that is obligated to consolidate the Financial Statement of Taxpayer. Taxpayer must fill out statement C-1 and C-2 by putting checkmark in the box in accordance with the conditions of Taxpayer. Taxpayer must fill out statement D in the form of data entry of Parent Entity, namely entity that: a. owns directly or indirectly one or more other Constituent Entity in the Business Group; b. has the obligation to organize consolidated Financial Statement based on financial accounting standards or the provisions applicable in the country or jurisdiction where the concerned entity is domiciled; and c. is not owned directly or indirectly by other Constituent Entity in the Business Group, or owned directly or indirectly by other entity, but the other entity is not obligated to consolidate the Financial Statement of the concerned entity. Number (2) : please fill out with information regarding name of Parent Entity. Number (3) : please fill out with information regarding NPWP or Taxpayer Registration Number (TIN) of Parent Entity. Number (4) : please fill out with information regarding country or jurisdiction where the Parent Entity is domiciled. Number (5) : please fill out with value of consolidated gross turnover of Parent Entity for the corresponding Fiscal Year in accordance with the functional currency of Parent Entity and indicate the alphabetical code of currency in accordance with the international standard, for example: Currency Rupiah United States Dollar Australian Dollar Singaporean Dollar Euro Pound Sterling Yen Alphabet Code IDR USD AUD SGD EUR GBP JPY Example: Value of consolidated gross turnover of Parent Entity is US$ 1,000,000, (one billion United States Dollar) 1,000,000, Number (6) : pleas fill out by providing the equivalent value in Euro currency for the consolidated gross turnover of Parent Entity that uses functional currency other than rupiah as determined based on the exchange value of functional currency of Parent Entity in 1 January Example: The value of consolidated gross turnover of Parent Entity with functional currency of United States Dollar is amounting to US$ 1,000,000, (one billion United States Dollar). For example, it is known that the conversion value of United States Dollar to Euro on 1 January 2015 is Thus, the value of consolidated gross turnover that is equivalent in Euro currency shall be 826,580, ,580,000.00

14 In the event that the functional currency of Parent Entity is rupiah, the blank in line number (6) does not need to be filled out. Taxpayer must fill out statement E, in the event that: a. there is more than one Resident Taxpayer that constitutes Constituent Entity of the same Business Group, and Parent Entity that constitutes foreign tax subject appoints one of the Constituent Entities that constitutes Resident Taxpayer to deliver the Country-to-Country Reports to the Directorate General of Taxation; or b. Parent Entity that constitutes foreign tax subject appoints Constituent Entity in overseas as the substitute of Parent Entity to deliver the Country-to-Country Reports to the tax authorities in Partner Country or Partner Jurisdiction where the Constituent Entity is domiciled. Taxpayer does not need to fill out statement E if the Parent Entity does not appoint Constituent Entity or substitute of Parent Entity to deliver Country-to-Country Reports as intended in guidelines for filling out statement E above. Number (7) : please fill out with information regarding name of Constituent Entity or substitute of Parent Entity. Number (8) : please fill out with information regarding NPWP or Taxpayer Registration Number (TIN) of the Constituent Entity or substitute of Parent Entity. Number (9) : please fill out with information regarding Country or Jurisdiction of domicile of Constituent Entity or substitute of Parent Entity. PART III. STATEMENT OF OBLIGATION OF DELIVERY OF COUNTRY-TO- COUNTRY REPORTS Taxpayer must fill out one of the statements in Part III by putting checkmark in one of the box in accordance with the condition of Taxpayer, under the following conditions: 1. statement F-1 is given checkmark in the event that Taxpayer states as Parent Entity, and it is obligated to organize, keep, and deliver the Country-to-Country Reports in accordance with the applicable provisions. 2. statement F-2 is given checkmark in the event that Taxpayer states as Parent Entity, however, it is not obligated to organize, keep, and deliver the Countryto-Country Reports in accordance with the applicable provisions. Nevertheless, the Taxpayer must fill out the reason in accordance with the actual condition. 3. statement F-3 is given checkmark if Taxpayer states not as Parent Entity, however, it is obligated to deliver the Country-to-Country Reports in accordance with the applicable provisions. 4. statement F-4 is given checkmark if Taxpayer states not as Parent Entity and it is not obligated to deliver the Country-to-Country Reports in accordance with the applicable provisions. However, the Taxpayer must fill out the reason in accordance with the actual condition. Number (10) : please fill out with reason in accordance with the actual condition related to the statement of Taxpayer that states as Parent Entity, however, it is not obligated to organize, keep, and deliver the Country-to-Country Reports in accordance with the applicable provisions. Number (11) : please fill out with reason in accordance with the actual condition related to the statement of Taxpayer that states not as Parent

15 Entity and it is not obligated to deliver Country-to-Country Reports in accordance with the applicable provisions. Number (12) : please fill out with name, title, and signature of representative of Taxpayer or the Proxy. Source: LOOSE LEAF OF REGULATION OF THE DIRECTOR GENERAL OF FISCAL YEAR 2017