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Urut Berdasarkan
 
Register : 08-01-2020 — Putus : 30-01-2020 — Upload : 12-05-2020
Putusan MAHKAMAH AGUNG Nomor 38 B/PK/PJK/2020
Tanggal 30 Januari 2020 — PT. QUEEN PACIFIC SUKSESABADI VS DIREKTUR JENDERAL BEA DAN CUKAI
8130 Berkekuatan Hukum Tetap
  • These productsare classified according to their constituent material,(A) Footwear may range from sandals with uppers consisting simply of adjustable laces orribbons to thighboots (the uppers of which cover the leg and thigh, and which may havestraps, etc., for fastening the uppers to the waist for better support).
    (A) Footwear may range from sandals with uppers consisting simply of adjustable laces orribbons to thnghboots (the uppers of which cover the leg and thigh, and which may havestraps, etc., for fastening the uppers to the waist for better support).
    In determining theconstituent material of the outer sole, no account should be taken of attached accessories orreinforcements which partly cover the sole (see Note 4 (b) to this Chapter).
    In such cases, the upper shall be considered to be thatportion of the shoe which covers the sides and top of the Tet, The size of the uppers variesvery much between different types of footwear, from those covering the foot and the wholeleg, including the thigh (for example, fishermens boots), to those which consist simply ofstraps or thongs (for example, gaisiciayIf the upper consists of two or more materials, classification is determined by theconstituent material which has the greatest external
Register : 26-07-2012 — Putus : 21-03-2013 — Upload : 14-07-2013
Putusan PENGADILAN PAJAK Nomor Put.44119/PP/M.VII/19/2013
Tanggal 21 Maret 2013 — Pemohon Banding dan Terbanding
10924
  • (http://www.cargotec.com) kedapatan bahwa Kalmar Terminal Tractors Model Ottawa4x2 adalah traktor jalan untuk semi trailer (Road Tractor for semitrailer) sebagaimanakutipan berikut :Cargotec procedures their Ottawa 4x2 terminal tractor which is a 4x2 tandem axle truckfor overtheroad transport (in North America) of containers and trailers. We also holdmany patents and is the only terminal factor manufacturer in the industry that preformstheir chassis frame rails from steel plate.
    The cab features power steering, automatic gear shifting,maximum visibility and a sharp turning radius, which provides our drivers with comfortwhile increasing productivity.
    In 1958, Ottawa Truck,which was later acquired by Kalmar, introduced the first terminal tractor manufactured in theUSA. Kalmar is the worldleading brand for terminal tractor technology.
    In 1958, Ottawa Truck,which was later acquired by Kalmar, introduced the first terminal tractor manufactured inthe USA.Cargotec produces their Ottawa 4X2 terminal tractor which is a 4X2 tandem axle truck forovertheroad transport (in North America) of containers and trailers.We also hold many patents and is the only terminal tractor manufacturer in the industry thatpreforms their chassis frame rails from steel plate.Our terminal tractor meets the requirements for demanding ergonomics.
    The cab featurespower steering, automatic gear shifting, maximum visibility and a sharp turning radius,which provides our drivers with comfort while increasing productivity.Kalmar terminal tractors can spot 3 trailers in the same time it takes an overtheroadtractor to spot I trailer.bahwa berdasarkan uraian tersebut Majelis menyimpulkan identifikasi barang adalah :Terminal Tractors merk Kalmar, model Ottawa 4x2 dalam keadaan SKD (Semi KnockedDown) yang penggunaannya adalah : Off Highway.Klasifikasi
Register : 23-03-2017 — Putus : 08-06-2017 — Upload : 24-07-2017
Putusan MAHKAMAH AGUNG Nomor 655 B/PK/PJK/2017
Tanggal 8 Juni 2017 — DIREKTUR JENDERAL PAJAK VS PT. ORICA MINING SERVICE;
9058 Berkekuatan Hukum Tetap
  • they arise, andaccording to the law of that State, but the tax so charged shall not exceed:(a) in the case of royalties described in subparagraphs 3 (b) and (c), and to theextent to which they relate to those royalties, in subparagraphs 3 (d) and (f) 10%; andHalaman 5 dari 25 halaman.
    In the knowhow contract, one of the parties agrees toimpart to the other, so that he can use them for his own account, his specialknowledge and experience which remain unrevealed to the public.
    Hal ini sesuai dengan definisi Orica Know Howdalam ETL Agreement sebagai berikut:Orica Know How means all trade secrets and Know How owned by or in thepossession of Orica or OET or any of either Controlled Companies or owned byor in the possession of a third party in and to which Orica or any of its controlledin and to which Orica or any of its Controlled Companies has a right to grantlicense and rights granted herein and which is used by Orica to provide servicesin relation to the manufacture of
    Putusan Nomor 655/B/PK/PJK/2017(a) in the case of royalties described in subparagraphs 3(b) and (c),and to the extent to which they relate to those royalties, insubparagraphs 3(d) and (f) 10%; and(b) in all other cases 15%.The competent authorities of the contracting states shall by mutualagreement settle the mode of application of these limitations.3.
    periodical or not, and however described or computed,to the extent to which they are made as consideration for:a. the use of, or the right to use, any copyright, patent, designor model, plan, secret formula or process, trademark orother like property or right; orbahwa sesuai dengan ketentuan P3B tersebut di atas, olehkarena nyatanyata Termohon Peninjauan Kembali telahHalaman 22 dari 25 halaman.
Register : 13-09-2013 — Putus : 19-11-2014 — Upload : 27-04-2016
Putusan PENGADILAN PAJAK Nomor Put-57557/PP/M.XVIIA/19/2014
Tanggal 19 Nopember 2014 — Pemohon Banding dan Terbanding
478609
  • It is also a dairy animal which is a source of milkand other dairy products like butter and cheese. Meanwhile, the ox is a draft animal. It isused to pull carts, plows, and sleds. It can also be used as a beast of burden for poweringtraditional agricultural machines like grain grinders or irrigation pumps.Most often than not, an ox is more intelligent than a cow. That is because an ox is a trainedanimal. It has been trained to respond correctly to the commands of its handler.
    So when you go to a farm,you will be able to identify which is the cow and which is the ox.http://ruralheritage.com/ox paddock/oxwhatis.htmAn ox, to early American farmers who used the beast, was a mature castrated malebelonging to the domestic cattle family, or genus Bos, most likely trained (like draft horses,some never got trained) to work, and at the end of its life inevitably used for meat.A steer, by contrast, is also a castrated male of the genus Bos, but is a younger animal thatmay not be
    In the UnitedStates a steer is not considered an ox until it is four years old, by which time it is consideredlarge enough and mature enough for any work required of it.In Australia and elsewhere, an ox is a called a "bullock."
    Same beast, but a different culture.New England teamsters sometimes call oxen "bulls," even though the animals have beencastrated.To be culturally and historically accurate when defining an ox, we must use the "right"definition as provided by the Random House Dictionary, which says that an ox is "The adultcastrated male of the genus Bos used as a draft animal and for food."
    Hence, by extension, all the Bovine are spoken of as cattle, wild or tame, a list of which follows. The group is characterized by its large size and bulky form and byvarious minor characteristics, of which the foremost is the roundness, smoothness,horizontal upcurving growth and comparative shortness of the horns.
Register : 13-07-2020 — Putus : 28-09-2020 — Upload : 02-08-2021
Putusan MAHKAMAH AGUNG Nomor 3460 B/PK/PJK/2020
Tanggal 28 September 2020 — PT. ALASINDO MAKMUR VS DIREKTUR JENDERAL BEA DAN CUKAI;
20933 Berkekuatan Hukum Tetap
  • Little oes)irrespective of their shape and size, the particular use for which they are designed, their methodof manufacture or the materials of which they are made.For the purposes of this Chapter, the term footwear does not, however, include disposable foot orshoe coverings of flimsy material (paper, sheeting of plastics, etc.) without applied soles. These productsare classified according to their constituent material,Halaman 7 dari 26 halaman.
    Putusan Nomor 3460/B/PK/Pjk/2020(A) Footwear may range from sandals with uppers consisting simply of adjustable laces orribbons to thighboots (the uppers of which cover the leg and thigh, and which may havestraps, etc., for fastening the uppers to the waist for better support).
    In determining theconstituent material of the outer sole, no account should be taken of attached accessories orreinforcements which partly cover the sole (see Note 4 (b) to this Chapter).
    In such cases, the upper shall be considered to be thatportion of the shoe which covers the sides and Ne of the foot.
    The size of the uppers variesvery much between different types of footwear, from those covering the foot and the wholeleg, including the thigh (for example, fishermens boots), to those which consist simply ofstraps or thongs (for example, sandals).If the upper consists of two or more materials, classification is determined by theconstituent material which has the pes external surface area, no account being taken ofaccessories or reinforcements such as ankle patches, protective or omamental strips
Register : 15-01-2020 — Putus : 17-02-2020 — Upload : 26-08-2020
Putusan MAHKAMAH AGUNG Nomor 443 B/PK/PJK/2020
Tanggal 17 Februari 2020 — PT. ALASINDO MAKMUR vs DIREKTUR JENDERAL BEA DAN CUKAI;
15727 Berkekuatan Hukum Tetap
  • Berdasarkan Explanatory Notes, penjelasan mengenai tentangChapter 64 in General, bahwa yang dimaksud footwear (10 jenisalas kaki), sebagai berikut:GENERALWith certain exceptions (see particularly those mentioned at the end of this General Note thisChapter covers, under headings 64,01 to 64.05, various types of footwear (including overshoes)irrespective of their shape and size, the particular use for which they are designed, their methodof manufacture or the materials of which they are made.For the
    Putusan Nomor 443/B/PK/Pjk/2020(A) Footwear may range from sandals with cree consisting simply of adjustable laces orribbons to thighboots (the uppers of which cover the leg and thigh, and which may havestraps, etc., for fastening the uppers to the waist for better support).
    Bahwa berdasarkan penelusuran pada sumber internet diketahuiThe term outer sole as used in headings 64.01 to 64.05 means that part of the footwear(other than an attached heel) which, na in use, is in contact with the ground. Theconstituent material of the outer sole for purposes of classification shall be taken to be thematerial having the greatest surface area in contact with the ground.
    In determining theconstituent material of the outer sole, no account should be taken of attached accessories orreinforcements which partly cover the sole (see Note 4 (b) to this Chapter).
    In such cases, the upper shall be considered to be thatportion of the shoe which covers the sides and top of the oor, The size of the uppers variesvery much between different types of footwear, from those covering the foot and the wholeleg, including the thigh (for peels, fishermens boots), to those which consist simply ofstraps or thongs (for example, sandals),If the upper consists of two or more materials, classification is determined by theconstituent material which has the greatest external surface
Register : 15-01-2020 — Putus : 17-02-2020 — Upload : 26-08-2020
Putusan MAHKAMAH AGUNG Nomor 464 B/PK/PJK/2020
Tanggal 17 Februari 2020 — PT. ALASINDO MAKMUR vs DIREKTUR JENDERAL BEA DAN CUKAI;
14932 Berkekuatan Hukum Tetap
  • Putusan Nomor 464/B/PK/Pjk/2020GENERALWith certain exceptions (see particularly those mentioned at the end of this General el thisChapter covers, under = 64.01 to 64,05, various types of footwear (including overshoes)irrespective of their shape ansize, the particular use for which they are designed, their methodof manufacture or the materials of which they are made,For the purposes of this Chapter, the term footwear does not, however, include ae foot orshoe coverings of flimsy material (paper, sheeting
    of plastics, etc.) without applied soles.hese productsare classified according to their constituent material,(A) Footwear may range from sandals with uppers consisting simply of adjustable laces orh if1()ribbons to thighboots (the uppers of which cover the leg and thigh, and which may havestraps, etc., for fastening the uppers to the waist for better support).
    which, when in use, is in contact with the oa, Teconstituent material of the outer sole for purposes of classification shall be taken to be thematerial having the greatest surface area in contact with the ground. In determining theconstituent material of the outer sole, no account should be taken of attached accessories orreinforcements which partly cover the sole (see Note 4 (b) to this Chapter).
    In such cases, the u per shall be considered to be thatportion of the shoe which covers the sides and top of the Foot.
    The size of the uppers variesvery much between different types of footwear, from those covering the foot and the wholeleg, including the thigh (for example, fishermens boots), to those which consist simply ofstraps or thongs (for example, sandals),If the upper consists of two or more materials, classification is determined by theconstituent material which has the preatest external surface area, no account being taken ofaccessories or reinforcements such as ankle patches, protective or oatanisital
Register : 15-07-2019 — Putus : 07-08-2019 — Upload : 09-08-2019
Putusan PT SEMARANG Nomor 385/PDT/2019/PT SMG
Tanggal 7 Agustus 2019 — Pembanding/Penggugat I : Ngabedan Diwakili Oleh : Ngabedan
Terbanding/Tergugat I : Kepala Koperasi Unit Desa KUD Sri Waluyaning Tani
Terbanding/Tergugat II : Kepala Kantor Pertanahan Kabupaten Kebumen
Turut Terbanding/Penggugat II : Towiyah
Turut Terbanding/Penggugat III : Yugi Woro Ariyani
Turut Terbanding/Penggugat IV : Yoga Wahyu Sasono
Turut Terbanding/Penggugat V : Irwan Danu Cahyana
Turut Terbanding/Penggugat VI : Suparno
Turut Terbanding/Penggugat VII : Sulastri
Turut Terbanding/Penggugat VIII : Muntiani
Turut Terbanding/Penggugat IX : Achmad Sudono
13485
  • This is in line with the stipulation of Article 613of the Criminal Code of Civil, which states as follows:"Credits transfer on the name and other intangible materials, shall beconducted by way of an authentic deed or in private, by which rightsover the materials are transferred to other persons.Such transfer for the debtors shall not cause any harm, but otherwiseafter such transfer is notified to him, or in writing approved andacknowledged."
    Whereas the definition of the project construction is the construction ofwheat flour milling factory of Defendant , which is located in Cilacap,Halaman 17, Putusan No. 385/Pdt/2016/PT SMGCentral Java ("Cilacap Flour Factory Project") .
    Service Supplier is a person or agency which business activitiesshall provide construction service.Whereas furthermore in Article 4 of Construction Service Law, it isregulated as follows:"Types of construction service, consists of construction planningissues, construction supervision issues which each to beconducted by a construction planner and construction supervisor.
    excess in Cilacap Flour Factory ProjectConstruction compared to the original budget;Whereas the result of PWC's audit showed that such delay has createdcost overrun which, until 30th April 1997, amounted to US$ 4,430,253.
    Amendment , No. 19 (seeExhibit P2), in which loss suffered by the Plaintiff is in the form offinancial loss for the money that lent to Defendant by the PlaintiffHalaman 22, Putusan No. 385/Pdt/2016/PT SMG failed to be used for the original purpose, which is to finance theproject construction in accordance with the budget.
Putus : 31-07-2015 — Upload : 11-03-2016
Putusan MAHKAMAH AGUNG Nomor 336/B/PK/PJK/2015
Tanggal 31 Juli 2015 — DIREKTUR JENDERAL PAJAK vs PT. MARUWA INDONESIA
6648 Berkekuatan Hukum Tetap
  • Where an enterprise of a Contracting State carries on business in the otherContracting State through a permanent establishment situated therein, thereshall in each Contracting State be attributed to that permanent establishmentthe profits which it might be expected to make if it were a distinct and separateenterprise engaged in the same of a similar activities under the same or similarconditions and dealing wholly independently with the enterprise of which it is apermanent establishment;3.
    In determining the profits of a permanent establishment, there shall be allowedas deductions expenses including executive and general administrativeexpenses, which would be deductible if the permanent establishment were anindependent enterprise, insofar, as they are reasonably allocable to thepermanent establishment, whether incurred in the State in which thepermanent establishment is situated or elsewhere;4. lf the information available to the competent authority is inadequate todetermine the profits
    by the exerciseof a discretion or the making of an estimate by the competent authority,provided that the law shall be applied, so far as the information available to thecompetent authority permits, in accordance with the principle of this Article;For the purpose of the preceding paragraphs, the profits to be attributed to thepermanent establishment shall be determined by the same method year byyear unless there is good and sufficient reason to the contrary;Where profits include items of income which
    Subject to the provisions of paragraph 3, where an enterprise of a ContractingState carries on business in the other Contracting State through a permanentestablishment situated therein, there shall in each Contracting State beattributed to that permanent establishment the profits which it might beexpected to make if it were a distinct and separate enterprise engaged in thesame of a similar activities under the same or similar conditions and dealingwholly independently with the enterprise of which
Putus : 20-11-2019 — Upload : 27-12-2019
Putusan MAHKAMAH AGUNG Nomor 4253/B/PK/Pjk/2019
Tanggal 20 Nopember 2019 — PT QUEEN PACIFIC SUKSESABADI vs DIREKTUR JENDERAL BEA DAN CUKAI
2818 Berkekuatan Hukum Tetap
  • Putusan Nomor 4253/B/PK/Pjk/2019GENERALWith certain exceptioms (see particularly those mentioned at the end of this General ote. thisChapter covers, under headings G4.01 to 64,05, various types of footwear (including overshoes)irrespective of their shape and size, the particuiar use for which they are designed, their methodof manufacture or the materials of which they are made.For the purposes of this Chapter, the term footwear ** docs not 2shoc coverings of flimsy matcrial (paper, sheeting of plastics
    , ctc.) without applied soles.according to their constituent material,mchuwde di SpCesrls foot orz hese productsare classifieCA) Footwear may range from sandals with uppers consisting simply of adjustable laces orribbons to thighboots (the uppers of which cower the leg and thigh, and which may haveStraps, etc., for fastening the uppers to the waist for better support).
    In determining theconstituent material of the outer sole, no account should be taken of attached accessories orreinforcements which partly cover the sole (see Note 4 (b) to this Chapter).
    In such cases, the upper shall be considered to be thatportion of the shoe which covers the sides and top of the foot.
    The size of the uppers variesvery much between different types of footwear, from those covering the foot and the wholeleg, including the thigh (for example, fishermens boots), to those which consist simply ofstraps or thongs (for example, sandals).If the upper consists of two or more materials, classification is determined by theconstituent material which has the prostest external surface area, no account being taken ofaccessories or reinforcements such as ankle patches, protective or ornamental
Putus : 17-02-2020 — Upload : 07-07-2020
Putusan MAHKAMAH AGUNG Nomor 225/B/PK/Pjk/2020
Tanggal 17 Februari 2020 — PT ALASINDO MAKMUR vs DIREKTUR JENDERAL BEA DAN CUKAI
6125 Berkekuatan Hukum Tetap
  • they are designed, their methodof manufacture or the materials of which they are made.For the purposes of this Chapter, the term footwear does not, however, include gsi foot orshoe coverings of flimsy material (paper, sheeting of plastics, etc.) without applied soles.hese productsare classified according to their constituent material,Halaman 10 dari 27 halaman.
    Putusan Nomor 225/B/PK/Pjk/2020(A)(C)(D)e.Footwear may range from sandals with uppers consisting simply of adjustable laces orribbons to thighboots (the uppers of which cover the leg and thigh, and which may havestraps, etc., for fastening the uppers to the waist for better support).
    In determining theconstituent material of the outer sole, no account should be taken of attached accessories orreinforcements which partly cover the sole (see Note 4 (b) to this Chapter).
    In such cases, the wu per shall be considered to be thatportion of the shoe which covers the sides and top of the foot.
    The size of the uppers variesvery much between different types of footwear, om those covering the foot and the wholeleg, including the thigh (for example, fishermens boots), to those which consist simply ofstraps or thongs (for example, avid).If the upper consists of two or more materials, classification is determined by theconstituent material which has the decal external surface area, no account being taken ofaccessories or reinforcements such as ankle patches, protective or ornamental strips oredging
Register : 22-05-2013 — Putus : 25-11-2014 — Upload : 22-12-2015
Putusan PENGADILAN PAJAK Nomor Put.57695/PP/M.IIA/13/2014
Tanggal 25 Nopember 2014 — Pemohon Banding dan Terbanding
40277
  • they arise,and according to the law of that State, but the tax so charged shall notexceed:(a) in the case of royalties described in subparagraphs 3(b) and (c), and to theextent to which they relate to those royalties, in subparagraphs 3(d) and (f) 10%; and(b) in all other cases 15%.The competent authorities of the Contracting States shall by mutual agreement settlethe mode of application of these limitations.Ayat (3) The term "royalties" in this Article means payments, whether periodical ornot,
    and however described or computed, to the extent to which they aremade as consideration for:(a) the use of, or the right to use, any copyright, patent, design or model, plan,secret formula or process, trademark or other like property or right; or(b) the use, or the right to use, any industrial, commercial or scientificequipment; or(c) the supply of scientific, technical, industrial or commercial knowledge orinformation; or(d) the supply of any assistance that is ancillary and subsidiary to, and isfurnished
    (a), any such equipment as ismentioned in subparagraph (b) or any such knowledge or information as ismentioned in subparagraph (c); or(f) total or partial forbearance in respect of the use or supply of any property orright referred to in this paragraph.bahwa Pemohon Banding mendalilkan pada Pasal 12 ayat (2) huruf (a) dan ayat (3)huruf (c) P3B a quo, sebagai berikut: The term "royalties" in this Article meanspayments, whether periodical or not, and however described or computed, to theextent to which
    In theknowhow contract, one of the parties agrees to impart to the other, so that he canuse them for his own account, his special knowledge and experience which remainunrevealed to the public.
    tentang Orica Know How,Menyediakan data elektronik yang dapat diakses berkaitan dengan Orica Know How.bahwa Terbanding mendalilkan pembayaran royalty atas penggunaan hak cipta,patent, desain model, perencanaan, rumus formula proses khusus dan menggunakannama dagang sebagaimana dimaksud dalam Pasal 12 ayat (8) huruf a P3B antaraIndonesia dengan Australia sebagai berikut: The term "royalties" in this Article meanspayments, whether periodical or not, and however described or computed, to theextent to which
Register : 30-07-2012 — Putus : 02-12-2013 — Upload : 21-03-2014
Putusan PENGADILAN PAJAK Nomor Put-48795/PP/M.I/15/2013
Tanggal 2 Desember 2013 — Pemohon Banding dan Terbanding
239169
  • Terbandingmelakukanpenentuakembalibesamyautanperusahaanyanberasaldaripihayanmemilikihubunganistimewamenjadimodaldengandasaprinsipkewajarandankelazimanusahyantidadipengaruhiolehhubunganistimewadengancaramembandingkadenganperusahaanyanhanyamelakukanpinjamakepadapihaindependen,dalahaliniadalah 6perusahaapembandingyansebandindenganPemohoBandingbahwa berdasarkan pembahasan dalam persidangan Majelis menyimpulkan bahwa sengketaBiaya Bunga ini terkait dengan konsep yang dikenal di perpajakan internasional sebagaiThinCapitalisation.Dari berbagai sumber,ono Fpoadcsnnderhanadapat dirujuk pengertian ataudefinisiThin Capitalisationmenurut otoritas perpajakan Inggris(HMRCHer MajestyRevenue&Customs,United Kingdom)yaituIntax terms a company(which
    dengan Indonesia,United Kingdommemberikan pedoman dasar yang antara lain berbunyiIn order to determine whether a company(or a group of companies)isthinly capitalised,itisnecessary to:ascertaihowmucthecompanyorcompanieswouldhavebeenabletoborrowfromanindependentlender(thearmlengthamount),andtocomparethiswiththeamountsactuallyborrowefromgroucompaniesorwiththebackinggroucompanies.ACcomparison can then be made between the interest payable on the actual debt and that whichwould be payable on the amount which
    tax purposes can be limited to those on the latter amount.bahwa HMRC dalam Statement of Practice04/07Juga menyatakan bahwa6.The basic transfer pricing rule applies where a provision is made between two persons bymeans of a transaction or series of transactions and one of the persons controls the other orboth are controlled by the same person or persons.Once a control relationship has been established,the basic rule then requires that the actualprovision be compared to the arms length provision(which
    pinjamannyabahwaOECD dalam salah satu laporannya tentangThin Capitalisation(adopted by OECDCouncil on26November 1986)yang dirujuk juga dalam OECD Model Convention,jugamenggambarkan bahwaThin Capitalisationbukanlah hal yang sederhana dan memerlukanperlakuan yang khusus.Laporan tersebut pada Para71juga menekankan kembalirekomendasi yang tercantum dalam laporan OECD tahun1979tentangTransfer Pricing andMultinational Enterprisesyang berbunyisgenerally recommended that a flexible approach should be adopted in which
Register : 05-04-2013 — Putus : 16-10-2014 — Upload : 13-11-2015
Putusan PENGADILAN PAJAK Nomor Put-56193/PP/M.IXB/19/2014
Tanggal 16 Oktober 2014 — Pemohon Banding dan Terbanding
14737
  • The first is ox, which is often restricted to animals of thegenus Bos (i.e. the wild cattle gaur, banteng, yak, aurochs, and kouprey as well asdomestic cattle). In popular use, though, the word 'ox' often refers to a castrated maleanimal, so that isn't a perfect solution. The second zoological term is bovine, whichis used as a noun to refer to any animal of the wider group that comprises cattle,buffaloes, and bison.
    So when you go to afarm, you will be able to identify which is the cow and which is the ox.http://ruralheritage.com/oxpaddock/oxwhatis.htmAn ox, to early American farmers who used the beast, was a mature castrated malebelonging to the domestic cattle family, or genus Bos, most likely trained (like drafthorses, some never got trained) to work, and at the end of its life inevitably used formeat.A steer, by contrast, is also a castrated male of the genus Bos, but is a youngeranimal that may not be trained
    In the United States a steer is not considered an ox until it is four years old,by which time it is considered large enough and mature enough for any work requiredof it.In Australia and elsewhere, an ox is a called a "bullock." Same beast, but a differentculture.
    New England teamsters sometimes call oxen "bulls," even though theanimals have been castrated.To be culturally and historically accurate when defining an ox, we must use the "right"definition as provided by the Random House Dictionary, which says that an ox is"The adult castrated male of the genus Bos used as a draft animal and forfood."Although, by United States standards, this definition is correct culturally, historically,and scientifically, it has its problems.
    It comes from the Latin word "capitale," which means wealthor property.The scientific name for cattle is bovine.A male bovine is called a bull. A female is called a cow, and sometimes a heifer.Young are called calves. Bullocks are castrated young bulls and steers are castratedolder bulls. Spayed heifers are desexualized females. A group of cattle is called aherd.Oxen are not a special breed of cattle, nor are they hybrids like mules.
Register : 06-11-2013 — Putus : 15-07-2014 — Upload : 29-06-2015
Putusan PENGADILAN PAJAK Nomor PUT-54052/PP/M.VIIB/19/2014
Tanggal 15 Juli 2014 — Pemohon Banding dan Terbanding
12430
  • Product which are wholly obtained or produced as set out and defined in Rule 3 ; or(b).
    Products not wholly prodused or obtained provided that the said products are eligible under Rule 4,Rule 5 or Rule 6;bahwa sesuai Overleaf Notes disebutkan bahwa if the products qualify under the above criteria,the exporter must indicate in box 8 of this form the origin criteria of the basis of which he claims that hisproducts qualify for preferential treatment, in the manner shown in the following tableCircumstances of production or manufacture in the first country named in box Insert in box 811
    or this formProducts wholly produced in the country of exportation (see paragraph 3 (i) woabove)(b) Products worked upon but not wholly produced in the exporting party which Percentage of singlewere produced in conformity with the provisions of paragraph 3 (ii) above country content, example40%(c) Products worked upon but not wholly produced in the exporting party which Percentage of ACFTAwere produced in conformity with the provisions of paragraph 3 (iii) above cumulative content,example 40%(d)
    Articles collected there which can no longer perform their original purpose nor are capable of beingrestored or repaired and are fit only for disposal or recovery of parts of raw materials, or for recyclingpurposes*; andj.. Good obtained or produced in a Party solely from products referred to in paragraphs (a) to (i) above; Plant here refers to all plant life including fruit, flowers, vegetables, trees, seaweed, fungi and liveplants,?
    covers all animal life, including mammals, birds, fish,crustaceans, molluscs, reptiles, bacteria and viruses,3 Products refer to those obtained from live animals without further processing, including milk, eggs,natural honey, hair, wool, semen and dung,4 This would cover all scrap and waste including scrap and waste resulting from manufacturing orprocessing operations or consumption in the same country, scrap machinery, discarded packagingand all products that can no longer perform the purpose for which
Putus : 27-02-2020 — Upload : 06-07-2020
Putusan MAHKAMAH AGUNG Nomor 518/B/PK/Pjk/2020
Tanggal 27 Februari 2020 — PT ALASINDO MAKMUR vs DIREKTUR JENDERAL BEA DAN CUKAI
5623 Berkekuatan Hukum Tetap
  • Putusan Nomor 518/B/PK/Pjk/2020GENERALWith certain exceptions (see particularly those mentioned at the end of this General Note) thisChapter covers, under headings 64.01 to 64.05, various types of footwear (including overshoes)irrespective of their shape and size, the particular use for which they are designed, their methodof manufacture or the materials of which they are made.For the purposes of this Chapter, the term footwear does not, however, include oo foot orshoe coverings of flimsy material
    These productsare classified according to their constituent material,(A) Footwear may range from sandals with uppers consisting simply of adjustable laces orribbons to thighboots (the uppers of which cover the leg and thigh, and which may havestraps, etc., for fastening the uppers to the waist for better support).
    (C) The term outer sole as used in headings 64.01 to 64.05 means that part of the footw(other than an attached heel) which, tai in use, is in contact with the ground. Theconstituent material of the outer sole for purposes of classification shall be taken to be thematerial having the greatest surface area in contact with the ground.
    In determining theconstituent material of the outer sole, no account should be taken of attached accessories orreinforcements which partly cover the sole (see Note 4 (b) to this Chapter).
    In such cases, the upper shall be considered to be thatportion of the shoe which covers the sides and top of the Tet, The size of the uppers variesvery much between different types of footwear, from those covering the foot and the wholeleg, including the thigh (for example, fishermens boots), to those which consist simply ofstraps or thongs (for example, sandals).if the upper consists of two or more materials, classification is determined by theconstituent material which has the preakest external
Putus : 09-03-2020 — Upload : 06-07-2020
Putusan MAHKAMAH AGUNG Nomor 525/B/PK/Pjk/2020
Tanggal 9 Maret 2020 — PT QUEEN PACIFIC SUKSESABADI vs DIREKTUR JENDERAL BEA DAN CUKAI,
6531 Berkekuatan Hukum Tetap
  • Note) thisChapter covers, under os 64.01 to 64.05, various types of footwear (including overshoes)irrespective of their shape and size, the particular use for which they are designed, their methodof manufacture or the materials of which they are made.d.Definisi Footwear meliputi sandal sampai thigh boots (footwear yangmenutup lutut) dan mengenai pengertian sol luar/outer solessebagaimana dimaksud pada pos No. 64.01 sampai dengan 64.05berarti bagian dari alas kaki (selain dari tumit yang dipasangkan
    Putusan Nomor 525/B/PK/Pjk/2020(A)(C)(D)boot yang terletak di atas sol sebagaimana dimaksud dalam huruf (A),(C) dan (D), GeneralExplanatory Notes Fifth Edition (2012), Chapter64, sebagai berikut:Footwear may range from sandals with uppers consisting mp of adjustable laces orribbons to thighboots (the uppers of which cover the leg and thigh, and which may havestraps, ctc., for fastening the uppers to the waist for better support).
    In determining theconstituent material of the outer sole, no account should be taken of attached accessones orreinforcements which partly cover the sole (see Note 4 (b) to this Chapter).
    In such cases, the u shall be considered to be thatportion of the shoe which covers the sides and top of the foot. The size of the uppers variesvery much between different types of footwear, from those covering the foot and the wholeleg, including the thigh (for example, fishermens boots), to those which consist simply ofstraps or thongs (for example, sandals). .e.
    Bahwa BTKI 2017 alas kaki dengan outer sole dan upper terbuat daribahan karet atau plastik, diklasifikasikan pada Pos Tarif 64.01 dan 64.02dengan uraian:64.01 Waterproof Footwear with outer soles and uppers of rubber or ofplastics, the uppers of which are neither fixed to the sole nor assembled bystitching, riveting, nailing, screwing, plugging or similar processes;64.02 Other footwear with outer soles and uppers of rubber or plastics.3.
Putus : 04-08-2015 — Upload : 10-03-2016
Putusan MAHKAMAH AGUNG Nomor 375 B/PK/PJK/2015
Tanggal 4 Agustus 2015 — PT. YASULOR INDONESIA VS DIREKTUR JENDERAL PAJAK
261250 Berkekuatan Hukum Tetap
  • differ from those which would be made between independententerprises (4)then any profits which would, but for those conditions, have accrued to one ofihe enterprises, but, by reason of those conditions, have not so accrued,may be included in the profits of that enterprise and taxed accordingly.
    Its conclusions are set out in the report entitledTransfer pricing Guidelines for Multinational Enterorises and TaxAdministrations, which is periodically updated to reflect the progress ofthe work of the Committee in this area. That report representsinternationally agreed principles and provides Guidelines for theapplication of the Arms length principle of which the Article is theauthoritative statement."
    Article 9 provides:(When) conditions are made or imposed between the two (associated) enterprises in theircommercial or financial relations which differ from those which would be made betweenindependent enterprises, then any profits which would, but for those conditions, have accrued toone of the enterprises, but, by reason of those conditions, have not so accrued, may beincludedin the profits of that enterprise and taxed accordingly." bahwa Commentary Article 9 OECD Model dan UN Model Article 9
    Putusan Nomor 375/B/PK/PJK/2015Statement number 3, page 1:Year 2008 profit margin is 5,5% which was established by headoffice. The margin was calculated using methodology endorsed byhead office.
    Putusan Nomor 375/B/PK/PJK/2015The new ruling, which was issued on 6 August 2008, affirms thatthe Full Cost markup does not require a distinction between costof goods sold and operating Expenses.
Putus : 30-01-2020 — Upload : 08-07-2020
Putusan MAHKAMAH AGUNG Nomor 463/B/PK/Pjk/2020
Tanggal 30 Januari 2020 — PT ALASINDO MAKMUR VS DIREKTUR JENDERAL BEA DAN CUKAI
30959 Berkekuatan Hukum Tetap
  • Berdasarkan Explanatory Notes, penjelasan mengenai tentangChapter 64 in General, bahwa yang dimaksud footwear (10 jenis alaskaki), sebagai berikut:GENERALWith certain exceptions (see particularly those mentioned at the end of this General Note) thisChapter covers, under headings 64.01 to 64.05, various types of footwear (including overshoes)irrespective of their shape and size, the particular use for which they are designed, their methodof manufacture or the materials of which they are made.For the
    These productsare classified according to their constituent material,(A) Footwear may range from sandals with uppers consisting seunty of adjustable laces orribbons to thighboots (the uppers of which cover the leg and thigh, and which may havestraps, etc., for fastening the uppers to the waist for better support).
    In determining theconstituent material of the outer sole, no account should be taken of attached accessories orreinforcements which partly cover the sole (see Note 4 (b) to this Chapter).
    In such cases, the upper shall be considered to be thatportion of the shoe which covers the sides and 9 of the foot.
    The size of the uppers variesvery much between different types of footwear, from those covering the foot and the wholeleg, including the thigh (for example, fishermens boots), to those which consist simply ofstraps or thongs (for example, sandals),If the upper consists of two or more materials, classification is determined by theconstituent material which has the premtest external surface area, no account being taken ofaccessories or reinforcements such as ankle patches, protective or omamental strips
Register : 05-04-2013 — Putus : 16-10-2014 — Upload : 13-11-2015
Putusan PENGADILAN PAJAK Nomor Put-56194/PP/M.IXB/19/2014
Tanggal 16 Oktober 2014 —
4315
  • The first is ox, which is often restricted to animals of thegenus Bos (i.e. the wid cattle gaur, banteng, yak, aurochs, and kouprey as well asdomestic cattle). In popular use, though, the word ox often refers to a castrated maleanimal, so that isnt a perfect solution. The second zoological term is bovine, whichis used as a noun to refer to any animal of the wder group that comprises cattle,buffaloes, and bison.
    It is also a dairy animal which is a sourceof milk and other dairy products like butter and cheese. Meanwhile, the ox is a draftanimal. It is used to pull carts, plows, and sleds. It can also be used as a beast ofburden for powering traditional agricultural machines like grain grinders or irrigationpumps.Most often than not, an ox is more intelligent than a cow. That is because an ox is atrained animal. It has been trained to respond correctly to the commands of itshandler.
    So when you go to afarm, you wil be able to identify which is the cow and which is the ox.http//rura lherita ge.com/oxpaddock/oxwhatis. htmAn ox, to early American farmers who used the beast, was a mature castrated malebelonging to the domestic cattle family, or genus Bos, most likely trained (like drafthorses, some never got trained) to work, and at the end of its life inevitably used formeat.A steer, by contrast, is also a castrated male of the genus Bos, but is a youngeranimal that may not be
    In the United States a steer is not considered an ox until it is four years old,by which time it is considered large enough and mature enough for any work requiredof it.In Australia and elsewhere, an ox is a called a "bullock." Same beast, but a differentculture.
    New England teamsters sometimes call oxen "bulls," even though theanimals have been castrated.To be culturally and historically accurate when defining an ox, we must use the "right"definition as provided by the Random House Dictionary, which says that an ox is"The adult castrated male of the genus Bos used as a draft animal and forfood."