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44 — 19 — 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
Putusan Nomor 4039/B/PK/Pjk/2019GENERALWith 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 oe aya 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 aes foot orshoe coverings of flimsy material (paper
Putusan Nomor 4039/B/PK/Pjk/2019GENERALWith 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 sisposenis foot orshoe coverings of flimsy
The size of the uppers variesvery much between different types of footwear, Fai those covering the foot and the wholeleg, including the thigh (for example, fishermens boots), to those which consist simply ofstraps or thongs (for example, savisiyIf the upper consists of two or more materials, classification is determined by theconstituent material which has the cat external surface area, no account being taken ofaccessories or reinforcements such as ankle patches, protective or omamental strips oredging
76 — 55 — Berkekuatan Hukum Tetap
Putusan Nomor 508 B/PK/Pjk/2020This document has been created with TX Text Control Trial Version 20.0 You can use this trial version for further 0 days.GENERALWith certain exceptions (see particularly those mentioned at the end of this General Nive 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
Putusan Nomor 508 B/PK/Pjk/2020This document has been created with TX Text Control Trial Version 20.0 You can use this trial version for further 0 days.GENERALWith certain exceptions (see particularly those mentioned at the end of this General ~ 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 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 prestest external surface area, no account being taken ofaccessories or reinforcements such as ankle patches, protective or cmamental strips
18 — 1
ou 6 8 g = S a & 2 a gl = Fo ecof fe 2 eG mie sh im ai ie ba atea oe am Sow cen & BS & %8 2 6 ie G ss mM Oo 5 3 ; : = Fs ae & foey from tg, sige as a . ia) f those me oe athe hvN 2s eu 2 x he Ee fe ee 3 2 iS Q2 9 ND & o 5 3 & G 2 @ ZB :, 7 S . 5 : FE &eee Ry = 3 > Be a eS ge on be ee (2 2 = S G a = @ 2 ew Bos Sy A 2 5 oO ae cae teEe * 2a Q 8 2 us 5 oS Ss = x w a4fe GR RS : & " 4 OU ot Oo = 5 & Be ee eo ; hee2 24222 ao a2 ao PSB EeEe P @ a Oo 2 So Ee 5 9 & > on) sf cre * Q 6 = 3 & ch 3g g gq @ . .
308 — 58 — Berkekuatan Hukum Tetap
Berdasarkan Explanatory Notes to the HS heading 64.02 dijelaskansebagaimana kutipan berikut:This heading covers footwear with outer soles and uppers of rubberor plastics, other than those of heading 64.01%d.
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
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
181 — 90 — Berkekuatan Hukum Tetap
Insuch a case, it is necessary to determine how themarketer should be compensated for those activities. Theissue is whether the marketer should be compensated asa service provider, i.e. for providing promotional services,or whether there are any cases in which the marketershould share in any additional return attributable to themarketing intangibles.
In that case, the distributor would beentitled to compensation appropriate to its agencyactivities alone and would not be entitled to share in anyreturn attributable to the marketing intangible;Where the distributor actually bears the cost of itsmarketing activities (i.e. there is no arrangement for theowner to reimburse the expenditures), the issue is theextent to which the distributor is able to share in thepotential benefits from those activities.
State shall make an appropriate adjustment to theamount of the tax charged therein on those profits.
In such a case, it Isnecessary to determine how the marketer should becompensated for those activities. The issue is whether themarketer should be compensated as a service provider, ..for providing promotional services, or whether there areany cases in which the marketer should share in anyadditional return attributable to the marketing intangibles.
In that case, the distributor would be entitled tocompensation appropriate to its agency activities alone andwould not be entitled to share in any return attributable tothe marketing intangible;6.38 Where the distributor actually bears the cost of itsmarketing activities (i.e. there is no arrangement for theowner to reimburse the expenditures), the issue is theextent to which the distributor is able to share in thepotential benefits from those activities.
44 — 2
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78 — 30 — Berkekuatan Hukum Tetap
Putusan Nomor 38/B/PK/Pjk/2020This document has been created with TX Text Control Trial Version 20.0 You can use this trial version for further 0 days.GENERALWith certain exceptions (see particularly those mentioned at the end of this General Note) thisChapter covers, under op 64,01 to 64.05, various types of footwear ene ee 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
Putusan Nomor 38/B/PK/Pjk/2020This document has been created with TX Text Control Trial Version 20.0 You can use this trial version for further 0 days.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
Putusan Nomor 38/B/PK/Pjk/2020This document has been created with TX Text Control Trial Version 20.0 You can use this trial version for further 0 days.GENERALWith certain exceptions (see particularly those mentioned at the end of this General ie 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
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
243 — 44 — 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 size of the uppers variesvery much between different types of footwear, fea 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 poses external surface area, no account being taken ofaccessories or reinforcements such as ankle patches, protective or omamental strips
122 — 56 — Berkekuatan Hukum Tetap
No.1041 K/Pid/2017.berkata Ibu... you can use those document including akta RUPS fosupport your argument for Nadine claim at the court to close PT. CastawayLife, yang artinya Ibu... kamu bisa pakai dokumendokumen termasukakta RUPS untuk mendukung argumen kamu pada tuntutan Nadine diPengadilan untuk menutup PT. Castaway Life.
Castaway Life Nomor 8 tanggal 16Oktober 2014 kepada Anggia M Lubis Brown sambil berkata Ibu... you canuse those document including akta RUPS to support your argument forNadine claim at the court to close PT. Castaway Life, yang artinya Ibu...kamu bisa pakai dokumendokumen termasuk akta RUPS untuk mendukungargumen kamu pada tuntutan Nadine di Pengadilan untuk menutup PT.Castaway Life.
Castaway LifeNomor 08 tanggal 16 Oktober 2014 kepada Anggia M Lubis Brown sambilberkata Ibu... you can use those document including akta RUPS fosupport your argument for Nadine claim at the court to close PT CastawayLife, yang artinya Ibu... kamu bisa pakai dokumendokumen termasukakta RUPS untuk mendukung argumen kamu pada tuntutan Nadine diPengadilan untuk menutup PT. Castaway Life.
Menurut Pemohon Kasasi duaanggota Majelis Hakim lebih condong kepada keterangan Terdakwa danmengabaikan keterangan saksisaksi yang lain antara lain Saksi AnggiaLubis Browne, yang di depan persidangan menerangkan bahwa Terdakwapernah mengatakan kepada Saksi Anggia M Lubis Brown Ibu... you canuse those document including akta RUPS fo support your argument forNadine claim at the court to close PT.
107 — 79 — Berkekuatan Hukum Tetap
Putusan Nomor 947/B/PK/PJK/20172. 8.the other Contracting State has been charged to tax in that otherState, and the profits so included are profits which would haveaccrued to the resident of the firstmentioned State if theconditions made between the two residents had been thosewhich would have been made between independent persons,then that other State shall make an appropriate adjustment tothe amount of the tax charged therein on those profits.
Insuch a case, it is necessary to determine how themarketer should be compensated for those activities.The issue is whether the marketer should becompensated as a service provider, .e. for providingpromotional services, or whether there are any casesin which the marketer should share in any additionalreturn attributable to the marketing intangibles.
In that case, thedistributor would be entitled to compensationappropriate to its agency activities alone and would notbe entitled to share in any return attributable to themarketing intangible;Where the distributor actually bears the cost of itsmarketing activities (i.e. there is no arrangement for theowner to reimburse the expenditures), the issue is theextent to which the distributor is able to share in thepotential benefits from those activities.
which wouldhave been made between independent persons, then thatother State shall make an appropriate adjustment to theamount of the tax charged therein on those profits.
Putusan Nomor 947/B/PK/PJK/20176.386.39appropriate to its agency activities alone and wouldnot be entitled to share in any return attributable tothe marketing intangible;Where the distributor actually bears the cost of itsmarketing activities (i.e. there is no arrangement forthe owner to reimburse the expenditures), the issueis the extent to which the distributor is able to sharein the potential benefits from those activities.
64 — 24
.; 2022 2o 2 one noe one eee2iion THOSE, 5.IH.f seeeeersncensnenaseeennnenenennmmannnt Cx Maman Usman R, 8.H., M.H.; Q 4. Astono H Gultom, S.H.; =e anne nena mene5. David Yody Pasaribu, S.H., M.H.; 6. J.P. Sinurat, S.H., M.H.; Kesemuanya berkewarganegaraan Indonesia, pekerjaan Advokatdan Penasihat Hukum, beralamat di Jalan Aki Balak RT. 60No. 95, Tarakan, berdasarkan Surat Kuasa Khusus Nomor :Hal. 3 dari 13 hal. Put.
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Putusan Nomor. 115 /B/PK/PJK/201 4aforesaids,tax may be imposed by that other Contracting State on thebusiness profits of such resident but only on so much of such profits asare attributable to the permanent establishment or are derived fromsources wthin such other Contracting State from sales of goods ormerchandise of the same kind as those sold, or from other businesstransactions of the same kinds as those effected, through the permanentestabtishment"Bahwa tagihan atas jasa dari Master Card International
If such resident carries on business asaforesaids, tax may be imposed by that other Contracting State on thebusiness profits of such resident but only on so much of such profits asare attributable to the permanent establishment or are derived fromsources wthin such other Contracting State from sales of goods ormerchandise of the same kind as those sold, or from other businesstransactions of the same kinds as those effected, through the permanentestablishment"Bahwa biaya yang Pemohon Banding catat
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If such resident carries on business asaforesaids,tax may be imposed by that other Contracting State on thebusiness profits of such resident but only on so much of such profits asare attributable to the permanent establishment or are derived fromsources within such other Contracting State from sales of goods ormerchandise of the same kind as those sold, or from other businesstransactions of the same kinds as those effected, through thepermanent estabtishment",Bahwa tagihan atas jasa dari Master Card
Putusan Nomor 112/B/PK/PJK/2014attributable to the permanent establishment or are derived from sourceswithin such other Contracting State from sales of goods or merchandise ofthe same kind as those sold, or from other business transactions of thesame kinds as those effected, through the permanent establishment";Bahwa Pasal 13 ayat 2 Persetujuan Penghindaran Pajak Berganda (P3B)antara Indonesia dan Amerika menyebutkan bahwa:"The rate of tax imposed by a Contracting State on royalties derived fromsources
111 — 27
or part of the floor slopes upwardstowards the rear:in some cases the driver's cab is halfwidth only:lack of axle suspension;high braking capacity:limited speed and area of operation:special earthmoving tyres:because of their sturdy construction the tare weight/payload ratio does not exceed 11.6;the body may be heated by exhaust gases to prevent materials from sticking orfreezing.It should be noted, however, that certain dumpers are specially designed for workingin mines or tunnels, for example, those
14 — 8
at ip tat : those Rp 50.000,00 Biaya Panggilan : Rp 475.000,00 Biaya Redaksi :Rp 10.000,00 PNBP :Rp 20.000,00 Biaya Meteral : Ro 6.000,00Jumlah :Rp 591.000,00(lima ratus Sembilan puluh satu ribu rupiah).Halaman 14 dari 14, Putusan Nomor 1019/Padt.G/2020/PA.Gsg
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In a narrow range of such cases, an intragroup activity maybe performed relating to group members even though those group members donot need the activity (and would not be willing to pay for it were theyindependent enterprises). Such an activity would be one that a group member(usually the parent company or a regional holding company) performs solelybecause of its ownership interest in one or more other group members, i.e. in itscapacity as shareholder.
If such resident carries on business as aforesaids, tax may be imposedby that other Contracting State on the business profits of such resident but onlyon so much of such profits as are attributable to the permanent establishment orare derived from sources within such other Contracting State from sales ofgoods or merchandise of the same kind as those sold, or from other businesstransactions of the same kinds as those effected, through the permanentestablishment.bahwa berdasarkan hal tersebut diatas
155 — 26 — 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
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
144 — 30 — 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
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
202 — 166
If the enterprise carries on business in that manner, the profits of the enterprise may be taxed in theother State but only so much of them as is attributable to:(a) that permanent establishment; or(b) sales in that other State of goods or merchandise of the same or a similar kind as those sold through thatpermanent establishment; or(c) other business activities carried on in that other State of the same or a similar kind as those carried onthrough that permanent establishment;(Laba suatu perusahaan
28 — 10
ikat pinggang 79 (tujuh piluh sembilan) cm, dan 1 (satu) utas tali warna kuning dengan panjang 58 (lima puluh delapan) cm, yang digunakan untuk mengikat ikat pinggang; 1 (satu) lembar kain adat Sumba Barat motif kain warna hitam, dengan garis warna ungu memanjang dari ujung kain hingga ke ujung kain dan terdapat pada pinggir kain motif gambar denga dasar warna hijau dan orange; 1 (satu) lembar baju switer warna biru dengan bagian depan bertuliskan FOR ALL THOSE
hijau, kuning,biru) terouat dari tali dengan panjang ikat pinggang 79 (tujuh piluhsembilan) cm, dan 1 (satu) utas tali warna kuning dengan panjang58 (lima puluh delapan) cm, yang digunakan untuk mengikat ikatpinggang;1 (satu) lembar kain adat Sumba Barat motif kain warna hitam,dengan garis warna ungu memanjang dari ujung kain hingga keujung kain dan terdapat pada pinggir kain motif gambar dengadasar warna hijau dan orange;1 (satu) lembar baju switer warna biru dengan bagian depanbertuliskan FOR ALL THOSE
kuning,biru) terouat dari tali dengan panjang ikat pinggang 79 (tujuh piluhsembilan) cm, dan 1 (satu) utas tali warna kuning dengan panjang58 (lima puluh delapan) cm, yang digunakan untuk mengikat ikatpinggang; 1 (satu) lembar kain adat Sumba Barat motif kain warna hitam,dengan garis warna ungu memanjang dari ujung kain hingga keujung kain dan terdapat pada pinggir kain motif gambar dengadasar warna hijau dan orange; 1 (satu) lembar baju switer warna biru dengan bagian depanbertuliskan FOR ALL THOSE
pinggang 79 (tujuh piluhHalaman 28 dari 32 Putusan Nomor 32/Pid.B/2014/PN WGP29sembilan) cm, dan 1 (satu) utas tali warna kuning dengan panjang58 (lima puluh delapan) cm, yang digunakan untuk mengikat ikatpinggang;1 (satu) lembar kain adat Sumba Barat motif kain warna hitam,dengan garis warna ungu memanjang dari ujung kain hingga keujung kain dan terdapat pada pinggir kain motif gambar dengadasar warna hijau dan orange;1 (satu) lembar baju switer warna biru dengan bagian depanbertuliskan FOR ALL THOSE
Nomor 32/Pid.B/2014/PN WGP31tali dengan panjang ikat pinggang 79 (tujuh piluh sembilan) cm, dan 1(satu) utas tali warna kuning dengan panjang 58 (lima puluh delapan) cm,yang digunakan untuk mengikat ikat pinggang;1 (satu) lembar kain adat Sumba Barat motif kain warna hitam, dengangaris warna ungu memanjang dari ujung kain hingga ke ujung kain danterdapat pada pinggir kain motif gambar denga dasar warna hijau danorange;1 (satu) lembar baju switer warna biru dengan bagian depan bertuliskan FOR ALL THOSE