of thatParty, provided that that Party has the rights to exploit such waters, seabed and beneath the seabedin accordance with international law,Products of sea fishing and other marine products taken from the high seas by vessels registeredwith a Party or entitled to fly the flag of that Party,Products processed and/or made on board factory ships registered with a Party or entitled to fly theflag of that Party, exclusively from products referred to in paragraph (g) above,Articles collected there which

of thatParty, provided that that Party has the rights to exploit such waters, seabed and beneath the seabedin accordance wth international law,Products of sea fishing and other marine products taken from the high seas by vessels registeredwth a Party or entitled to fly the flag of that Party,Products processed and/or made on board factory ships registered with a Party or entitled to fly theflag of that Party, exclusively from products referred to in paragraph (g) above,Articles collected there which

However, such interest may also be taxed in the State in which it arisesand according to the laws of that State, but if the beneficial owner of theHalaman 11 dari 33 halaman. Putusan Nomor277/B/PK/PJK/2013interest is a resident of the other State, the tax so charged shall notexceed 10 per cent of the gross amount of the interest.3.

For these reasons,the report from the Committee on Fiscal Affairs entitled "DoubleTaxation Conventions and the Use of Conduit Companies"concludes that a conduit company cannot normally be regarded asthe beneficial owner if; though the formal owner, it has, as apractical matter, very narrow powers which render it, in relation tothe income concerned, a mere fiduciary or administrator acting onaccount of the interested parties".14.2.

Yahya HarahapSH, Hukum Acara Perdata, Gugatan, Persidangan, Penyitaan,Pembuktian dan Putusan Pengadilan, Penerbit Sinar Grafika, hal. 830);Bahwa dalam Yurisprudensi, putusan yang diambil mengandungpertimbangan yang mendasar yaitu ratio decidendi atau basic reason,berupa prinsip hukum yang dijadikan dasar putusan yang diambil (theprinciple of law which the decision is based), dan putusan yang dijatuhkanmerupakan kasus yang berhubungan dengan perkembangan hukum (/awdevelopment), sehingga pada hakekatnya

CRN. 18014801,which my brother was handling, amount to send to Supplier account in Brazil. On 7" of March2018, my financial person received another email from my brother inBrazil(f.giamminola@groupltg.com), to request to remit the money into the followingIndonesia account:Account : L TRADE PTE LTD Bank Address: KCP Saharjo Branch Jakarta JI.Prof.Dr.Supomo SH No.32 JakartaSelatan.6.

The total amount is USD126,801.91(approx. 994,773), that is also the total loss ofthe case.& On 19" March 2018, we communicate through phone and started discussing aboutthe transaction because the supplier in Brazil did not receive the money which I remitted, andfinally we discovered that the email sent on 12" of March 2018 was fake, there is one letterwas changed. And VTC3 stated that his computer was hacked by hacker and sent the wronginstruction. So J think we were deceived.

The statement am about to make is true to the best of my knowledgeand belief and make it knowing that if I willfully state anything which I know to be false or do not believe to bg true, I maybe liable to prosecution for a criminal offence.Witnessed by auInterpreted byI am the abovestated person. I was born in Italy, would like to make a furtherstatement to correct the bank account which remitted and taken by DPC 19632.2.

Bahwa Pasal 12 Ayat 1, Ayat 2 dan Ayat 3 Perjanjian Penghindaran PajakBerganda antara Pemerintah Republik Indonesia dengan Pemerintah Jepangmenyebutkan sebagai berikut :1 Royalties arising in a Contracting State and paid to a resident of the other theContracting State may be taxed in that other Contracting State.2 However, such royalties may also be taxed in the Contracting State in which theyarise, and according to the laws of that Contracting State, but if the recipient is thebeneficial owner of

Bahwa Pasal 12 Ayat 1, Ayat 2, Ayat 3 dan Ayat 4 Perjanjian Penghindaran PajakBerganda antara Pemerintah Republik Indonesia dengan Pemerintah Singapuramenyebutkan sebagai berikut :1 Royalties arising in a Contracting State and paid to a resident of the otherContracting State may be taxed in that other State.2 However, such royalties may be taxed in the Contracting State in which they arise,and according to the law of that State, but if the recipient is the beneficial owner of theroyalties, the tax

(b) The term "royalties" as used in this Article also includes payments by aresident of one of the Contracting States for the use of, or the right touse, industrial, commercial or scientific equipment, but not includingships, aircraft or containers the income from which is exempt from taxby the other Contracting State under Article 9 (Shipping and AirTransport).9.

However, such interst may also be taxed in the State in which itarises according to the laws of that State, but if the BeneficialOwner of the interst is a resident of the other State, the tax socharged shall not exceed 10 percent of the gross amount of theinterest;bahwa Terjemahan Pasal 11 tersebut adalah sebagai berikut:a. Bunga yang timbul di salah satu Negara dan dibayarkan kepadapenduduk Negara lainnya dapat dikenakan pajak di Negaralainnya;b.

diterapkan apabilaterpenuhi persyaratan bahwa Dupoer Finance BV merupakanBeneficial Owner dari penghasilan bunga yang diterimanya;Ketentuan Pasal 11 P3B Indonesia Belanda mengatur mengenaipemajakan atas penghasilan bunga, yang redaksinya berbunyisebagai berikut:a.Interest arising in a Contracting State and paid to a resident ofthe other Contracting State may be taxed in that other state;However, subject to the provisions of paragraph 3, such interestmay also be tmed in the Contracting State ini which

Putusan Nomor 855/B/PK/PJK/20158)such cases, the factual circumstance of each individual case areof crucial importance,which make it difficult to provide moreprecise description;e the meaning of the term "benefical owner" in international taxlaw is strongly determined by factual cirmstances. It is thereforenot possible to give further meaning to this term in a generalmanner.

., milk enriched in vitamins ormineral salts), small quantities of stabilizingagents which serve to maintain the naturalconsistency of the product during transport inliquid state (disodium phosphate, trisodiumcitrate and calcium choride, for instance) aswell as very small quantities of anti oxidantsor vitamins not normaly found in the product.Certain of these products may also contain smallquantities chemicals (e.g., sodium bicarbonate)necessary for their processing; product in theform of powder

Preparations in powder or liquid from usedas infant food or for dietetic, purpose andconsisting of milk to which secondaryingredients (e.g., cereal, groats, yeast) havebeen added ;(2). Milk preparations obtained by replacingone or more constituents of milk (e.g., butyricfats) by another substances ;Berdasarkan Explanatory Notes to The HarmonizedHal. 13 dari 22 hal. Put.

., milk enriched in vitamins ormineral salts), small quantities of stabilising agents which serve tomaintain the natural consistency of the e product during transport inliquid state (disodium phosphate, trisodium citrate and calcium choride,for instance) as vell as very small quantities of antioxidants or vitaminsnot normany found in the product.

Thus heading 19.01 includes, for example:(1) Preparations in powder or liquid from used as infant food or for dieteticpurposes and consisting of milk to which secondary ingredients (e.g.

., milk enriched in vitamins or mineral salts),small quantities of stabilising agents which serve to maintain the naturalconsistency of the e product during transport in liquid state (disodiumphosphate, trisodium citrate and calcium choride, for instance) as well asvery small quantities of antioxidants or vitamins not normany found in theproduct.

Thus heading 19.01 includes, for example:(1) Preparations in powder or liquid from used as infant food or for dieteticpurposes and consisting of milk to which secondary ingredients (e.g.,cereal, groats, yeast) have been added.(2) Milk preparations obtained by replacing one or more constituents of milk(e. g., butyric fats) by another substances.Hal. 9 dari20 hal. Put.

., milk enriched in vitamins or mineral salts), smallquantities of stabilising agents which serve to maintain the natural consistency ofthe e product during transport in liquid state (disodium phosphate, trisodiumcitrate and calcium choride, for instance) as well as very small quantities of antioxidants or vitamins not normany found in the product.

Thusheading 19.01 includes, for example:(1) Preparations in powder or liquid from used as infant food or for dieteticpurposes and consisting of milk to which secondary ingredients (e.g., cereal,groats, yeast) have been added.(2) Milk preparations obtained by replacing one or more constituents of milk (e. g.

., milk enriched in vitaminsor mineral salts), small quantities of stabilising agents which serveto maintain the natural consistency of the product during transportin liquid state (disodium phosphate, trisodium citrate and calciumchloride, for instance) as well as very small quantities of antioxidants or vitamins not normally found in the product. Certain ofthese products may also contain small quantities chemicals (e.g.

Thus heading 19.01 inclucies, for example :(1) Preparations in powder or liquid from used as infant food or fordietetic purposes and consisting of milk to which secondaryingredients (e.g., cereal, groats, yeast) have been added ;(2) Milk preparations obtained by replacing one or more constituents ofmilk (e.g., butyric fats) by another substances ;Berdasarkan Explanatory Notes to the Harmonized System tersebut diatas, sangat jelas ditentukan bahwa suatu produk dapat diklasifikasikanHS 1901.10.29.00

., milk enriched in vitamins ormineral salts), small quantities of stabilising agents which serve tomaintain the natural consistency of the product during transport inliquid state (disodium phosphate, trisodium citrate and calciumchloride, for instance) as well as very small quantities of antioxidants or vitamins not normally found in the product. Certain ofthese products may also contain small quantities chemicals (e.g.

Thus heading 19.01 inclucies, for example :(1) Preparations in powder or liquid from used as infant food or fordietetic purposes and consisting of milk to which secondaryingredients (e.g., cereal, groats, yeast) have been added ;(2) Milk preparations obtained by replacing one or more constituents ofmilk (e.g., butyric fats) by another substances ;Berdasarkan Explanatory Notes to the Harmonized System tersebut diatas, sangat jelas ditentukan bahwa suatu produk dapat diklasifikasikanHS 1901.10.29.00

., milk enriched in vitamins or mineral salts),small quantities of stabilising agents which serve to maintain the naturalconsistency of the e product during transport in liquid state (disodiumphosphate, trisodium citrate and calcium choride, for instance) as well asvery small quantities of antioxidants or vitamins not normany found in theproduct.

Thus heading 19.01 includes, for example:(1) Preparations in powder or liquid from used as infant food or for dieteticpurposes and consisting of milk to which secondary ingredients (e.g.,cereal, groats, yeast) have been added.(2) Milk preparations obtained by replacing one or more constituents of milk(e. g., butyric fats) by another substances.Hal. 9 dari 20 hal. Put.

However, such interest may also be taxed in the State in which it arisesand according to the laws of that State, but if the beneficial owner of theinterest is a resident of the other State, the tax so charged shall notexceed 10 per cent of the gross amount of the interest ;Halaman 11 dari 33 halaman. Putusan Nomor316/B/PK/PJK/20133.

Putusan Nomor316/B/PK/PJK/2013Fiscal Affairs entitled "Double Taxation Conventions and the Use ofConduit Companies" concludes that a conduit company cannotnormally be regarded as the beneficial owner if; though the formalowner, it has, as a practical matter, very narrow powers which renderit, in relation to the income concerned, a mere fiduciary oradministrator acting on account of the interested parties",14.2.

Yahya HarahapSH, Hukum Acara Perdata, Gugatan, Persidangan, Penyitaan,Pembuktian dan Putusan Pengadilan, Penerbit Sinar Grafika, hal. 830);Bahwa dalam Yurisprudensi, putusan yang diambil mengandungpertimbangan yang mendasar yaitu ratio decidendi atau basic reason,berupa prinsip hukum yang dijadikan dasar putusan yang diambil (theprinciple of law which the decision is based), dan putusan yang dijatuhkanmerupakan kasus yang berhubungan dengan perkembangan hukum (/awdevelopment), sehingga pada hakekatnya

., milk enriched in vitaminsor mineral salts), small quantities ofstabilizing agents which serve to maintain thenatural consistency of the product duringtransport in liquid state (disodium phosphate,trisodium citrate and calcium choride, forinstance) as well as very small quantities ofanti oxidants or vitamins not normaly found inthe product. Certain of these products mayalso contain small quantities chemicals (e.g.

Preparations in powder or liquid fromused as infant food or for dietetic purposesand consisting of milk to which secondaryingredients (e.g., cereal, groats, yeast)have been added ;(2). Milk preparations obtained by replacingone or more constituents of milk (e.g.

., milk enriched in vitaminsor mineral salts), small quantities of stabilising agents which serveto maintain the natural consistency of the product during transportin liquid state (disodium phosphate, trisodium citrate and calciumchloride, for instance) as well as very small quantities of antioxidants or vitamins not normally found in the product. Certain ofthese products may also contain small quantities chemicals (e.g.

Thus heading 19.01 inclucies, for example :(1) Preparations in powder or liquid from used as infant food or fordietetic purposes and consisting of milk to which secondaryingredients (e.g., cereal, groats, yeast) have been added ;Hal. 8 dari 19 hal. Put.

., milk enriched in vitaminsor mineral salts), small quantities of stabilising agents which serveto maintain the natural consistency of the product during transportin liquid state (disodium phosphate, trisodium citrate and calciumchloride, for instance) as well as very small quantities of antioxidants or vitamins not normally found in the product. Certain ofthese products may also contain small quantities chemicals (e.g.

Thus heading 19.01 inclucies, for example :(1) Preparations in powder or liquid from used as infant food or fordietetic purposes and consisting of milk to which secondaryingredients (e.g., cereal, groats, yeast) have been added ;(2) Milk preparations obtained by replacing one or more constituents ofmilk (e.g., butyric fats) by another substances ;Berdasarkan Explanatory Notes to the Harmonized System tersebut diatas, sangat jelas ditentukan bahwa suatu produk dapat diklasifikasikanHS 1901.10.29.00

., milk enriched in vitaminsor mineral salts), smal quantities ofstabilizing agents which serve to maintain thenatural consistency of the product duringtransport in liquid state (disodium phosphate,trisodium citrate and calcium choride, forinstance) as well as very small quantities ofanti oxidants or vitamins not normaly found inthe product. Certain of these products mayalso contain small quantities chemicals (e.g.

Preparations in powder or liquid fromused as infant food or for dietetic purposesand consisting of milk to which secondaryingredients (@.g., cereal, groats, yeast)have been added ;(2). Milk preparations obtained by replacingone or more constituents of milk (e.g.

., milk enriched in vitamins ormineral salts), small quantities of stabilising agents which serve tomaintain the natural consistency of the product during transport inHal. 8 dari 20 hal. Put. No. 38/B/PK/PJK/2010liquid state (disodium phosphate, trisodium citrate and calciumchoride, for instance) as vell as very small quantities of antioxidantsor vitamins not normaly found in the product.

Thus heading 19.01 includes, for example :(1) Preparations in powder or liquid from used as infant food or for dieteticpurposes and consisting of milk to which secondary ingredients (e.g.

If LESSEE fails to pay any rent, Component ReserveCharge, if any, or other amount herein provided within ten (10)calendar days from and after the date upon which the same is dueand payable, then LESSEE shall be deemed to be in default....;Terjemahan resmi Pasal 23.1. Perjanjian Sewa:Seluruh ketentuan dalam Pernanjian ini harus dilaksanakan tepatpada waktunya.

(a) ..... terminate the agreement and take possession or control ofany object to which the agreement relates; 0r;(b) apply for a court order authorising or directing either of theseApabila terjadi wanprestasi berdasarkan peranjian pengikatanhak atau berdasarkan perjanjian sewa sebagaimana dimaksuddalam Pasal 11, penjual bersyarat atau pemberi sewa, sesuai dengan keadaannya,dapat:(a) bees mengakhini = penanyjian dan menguasai ataumengendalikan setiap objek yang terkait denganperjanjian tersebut; atau

BerikutkutiDannya: 222 nnn nnn nn nnn nnn nn nnn nnn nnn nn nnn cnn nen neePasal 43 (1) Konvensi Cape Town:.... the courts of the Contracting State on the territory of which theobject is situated have jurisdiction to grant relief under Article 13(1)(a), (b), (c) and Article 13(4) in respect of that object;Terjemahan resmi Pasal 43 (1) Konvensi Cape Town: Penetapan Perkara Perdata Nomor 142/Pdt.P/2019/PN.Tim.