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

AdapunPerkara No. 184 telah diputusoleh Majelis Hakim padaPengadilan Negeri Batamsebagaimana tertuang dalamPutusan No.Delimax Indonesia, in which theFirst Party holds 285.000 (twohundred eighty five thousand)shares of PT Delimax Indonesiawhich is 95 % (ninety fivepercent) of the entire shares inPT Delimax Indonesia, asstipulated in the Articles ofAssociation of Limited LiabilityCompany PT Delimax Indonesia,Number 80, dated 19 June 2013,made before Anly Cenggana,S.H., Notary in Batam (Articlesof Association

of PT DelimaxIndonesia).That the Second Party isone of the shareholders in PTDelimax Indonesia, in which theSecond Party holds 15,000(fifteen thousand) shares of PTDelimax Indonesia, which is 5%(five percent) of the entire sharesin PT Delimax Indonesia.That the Second Party wasappointed by the shareholders ofPT Delimax Indonesia as theDirector of PT Delimax Indonesiaon 19 June 2013, as stipulated inthe Articles of Association of PTDelimax Indonesia.That on 7 August 2019, theFirst Party has filed

a TortLawsuit against the SecondParty before the District Court ofBatam which regisetered as theCase No.184/PDT.G/2019/PN.Btm (CaseNo. 184).

1.8list of original documents whichmust be returned by the SecondParty are listed in Appendix 1 ofthis Settlement Agreement.The Second Party to transfer allof Second Partys shares in PTDelimax Indonesia amounting15,000 (fifteen thousand) shares,which is 5% (five percent) of theentire shares in PT DelimaxIndonesia to a person or legalentity aS appointed by the FirstParty at the same day of thesigning of this SettlementAgreement, all notary fees andtaxes incurred are borne by theFirst Party.The Second

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

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

pegawai;bahwa definisi Produk berarti bahan las, peralatan las, peralatan keselamatan dari jenisapapun yg selanjutnya diuraikan pada Lampiran I dan produk lain yang disepakati olehCigweld Pty Ltd dan Pemohon Banding secara tertulis dari waktu ke waktu di kemudianhari;bahwa berdasarkan penelitian Majelis terhadap pengertian Royalty sebagaimana diaturdalam Pasal 12 P3B Indonesia Australia adalah sebagai berikut :MenurutTerbanding1.2.Royalties arising in one of the Contracting States, being royalties to which

a resident ofthe other Contracting State is beneficially entitled, may be taxed in that other State;Those royalties may be taxed in the Contracting State in which they arise, andaccording to the law of that State, but the tax so charged shall not exceed:(a) inthe case of royalties described in subparagraphs 3(b) and (c), and to the extentto which they relate to those royalties, in subparagraphs 3(d) and (f) 10%; and(b) inall other cases 15%;The competent authorities of the Contracting States shall

by mutual agreement settlethe mode of application of these limitations;The term royalties in this article means payments, whether periodical or not, andhowever described or computed, to the extent to which they are made as considerationfor:a.

Berdasarkan General Exlanatory Notes Chapter 64 paragraphs (C)and (D) diketahui juga pengertian mengenai sol luar/out sole danpagian atas/upper sebagaimana berikut:(C) The term outer sole as used in headings 64.01 to 64.05 means that part of the footwearfother than an attached heel) which, when in use, is 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 nee 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 these 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 preaest external surface area, no account being taken ofaccessories or reinforcements such as ankle patches, protective or omamental strips

Berdasarkan General Explanatory Notes Chapter 64, pada alineapertama disebutkan 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 Gncieting grextnoerirrespective of their shape and size, the particular use for which they are designed, their methodof manufacture or the materials of which they are made.f.

The first is 'ox', which is often restricted to animals of the genus Bos(i.e. the wild cattle gaur, banteng, yak, aurochs, and kouprey as well as domestic cattle). Inpopular use, though, the word ox' often refers to a castrated male animal, so that isn't aperfect solution. The second zoological term is 'bovine, which is used as a noun to refer toany animal of the wider group that comprises cattle, buffaloes, and bison.

Such infertility is a result of beingmaternally twinned with a bull calf which placental tissues were shared in the womb.During the first trimester, reproductive organs start to form and sexual hormones beginto be produced in the fetus. When male and female fetal calves are twinned together, thetestosterone produced by the male inhibits estrogen production in the female.

So when you go to a farm,you will be able to identify which is the cow and which is the ox.g) http://ruralheritage.com/oxpaddock/oxwhatis.htmAn ox, to early American farmers who used the beast, was a mature castrated male belongingto the domestic cattle family, or genus Bos, most likely trained (like draft horses, some nevergot 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

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."

they are jointly andseverally liable;To C6 RM 210,884,780 by R3 to the intent that its liability will be reducedby any payment made under 1;To C7 US$ 5,773,134 by R1, R2, and R3 for which they are jointly andseverally liable;To C7 US$ 15,659,174 by R3 to the intent that its liability will be reducedby any payment made under 3;To 08 US$ 59,327,055 by R1, R2, and R3 for which they are jointly andseverally liable;To C8 US$ 151,281,770 by R3 to the intent that its liability will bereduced by any payment

RI and R2 are liable for 49% ofthis amount which is US$77042744 US$7, 149,848.Following our conclusions in part three the tribunal awards and orders thatrestitution shoud be made and paid as follows:To C8 US$591327055 US$59,459,258 by RI, R2 and R3 for which they areJointly and severally liable;Terjemahan resmi dalam Bahasa Indonesia:"Saluran Perubahhaluan:Nilai total (tidak termasuk pajak) yang dituntut atas 21 saluran perubahhaluan yang diperoleh dari para pembeli lisensi pihak ketiga adalahUS$22,741,577

Nomor 26 PK/Pat.SusArbt/2016stake in the reference which has (until now) been very hard fought at everystage. The issues were complex and the documents voluminous. TheTribunal see no reason to reduce any award for costs simply on the basisthat the amounts claimed are excessive;19.In principle, the Claimants should have their costs as the obviouslysuccessful party.

To C6:RM35,974,386 by R1, R2 and R3 for which they are jointly andseverally liable;ii. Further, to C6: RM73,417, 116 by R3 to the intent that its liability will bereduced by any payment under (1);iii. To C7: US$1,397,493 by R1, R2 and R3 for which they are jointly andseverally liable;iv. Further, to C7: US$4,123,497 by R3 to the intent that its liability would bereduced by any payment under (iii);v. To C8 US$14,531,934 by R1, R2 and R32 for which they are jointly andseverally liable;vi.

For the reasons set out above, the Tribunal apportions the total costs of thearbitration as between the Claimants and the Respondents as follows:Claimants: NilRespondents: 100%Any enforcement of this part of the Award against the Respondents shouldtake account of deposits which they have paid to SIAC of S$617,217.48 andthe sum of S$150,708 paid directly to the Claimants following the hearing inLondon in September 2009;Halaman 12 dari 41 hal. Put. Nomor 26 PK/Padt.SusArbt/20163.

memenuhi syarat kedua karena pembuatannya dengancara injection moulding, karena untuk masuk pos 64.02 harusmemenuhi syarat pembuatannya dengan cara dijahit, dikeling,dipaku, disekrup, ditusuk atau dengan cara semacam itu;Bahwa pada penjelasan pos 64.02 pada halaman XII 64021Explanatory Notes, Fifth Edition, Volume 3, dinyatakan : TheHeading covers, inter alia:(a) Ski boots consisting of several moulded parts hinged on rivetsor similar devices;(b) Clogs without quarter or counter, the uppers of which

areproduced in one piece usually attached to the base or platformby riveting;(c) Slippers or mules without quarter or counter,the uppers of which,being produced in one piece or assembled other than bystitching, are attached to the sole by stitching;(d) Sandals consiting of straps across the instep and counter orheelstrap attached to the sole by any process;(e) Thongtype sandals in which the thongs are attached to the soleby plugs which lock into holes in the sole;(f) Nonwaterproof footwear produced

Bahwa pada penjelasan pos 64.02 pada halaman XIl 64021Explanatory Notes, Fifth Edition , Volume 3, dinyatakan: The Headingcovers, inter alia:(a) Skiboots consisting of several moulded parts hinged on rivets orsimilar devices;(b) Clogs without quarter or counter, the uppers of which are producedin one piece usually attached to the base or platform by niveting;(c) Slippers or mules without quarter or counter, the uppers of which,being produced in one piece or assembled other than by stitching,are attached

to the sole by stitching;(d) Sandals consisting of straps across the instep and counter orheelstrap attached to the sole by any process;(e) Thongtype sandals in which the thongs are attached to the sole byplugs which lock into holes in the sole;(f) Nonwaterproof footwear produced in one piece (for example,bathing slippers);1.

(b) Clogs without quarter or counter, the uppers of which areproduced in one piece usually attached to the base or platform byriveting;(c) Slippers or mules without quarter or counter,the uppers of which,being produced in one piece or assembled other than by stitching,are attached to the sole by stitching;(d) Sandals consiting of straps across the instep and counter orheelstrap attached to the sole by any process;(e) Thongtype sandals in which the thongs are attached to the soleby plugs which lock

belumkelihatan memenuhi syarat kedua karena pembuatannya dengancara injection moulding, karena untuk masuk pos 64.02 harusmemenuhi syarat pembuatannya dengan cara dijahit, dikeling,dipaku, disekrup, ditusuk atau dengan cara semacam itu.Bahwa pada penjelasan pos 64.02 pada halaman XII 64021Explanatory Notes, Fifth Edition, Volume 3, dinyatakan: The Headingcovers, inter alia:(a) Ski boots consisting of several moulded parts hinged on rivetsor similar devices;(b) Clogs without quarter or counter, the uppers of which

areproduced in one piece usually attached to the base or platformby riveting;(c) Slippers or mules without quarter or counter,the uppers of which,being produced in one piece or assembled other than bystitching, are attached to the sole by stitching;(d) Sandals consiting of straps across the instep and counter orheelstrap attached to the sole by any process;(e) Thongtype sandals in which the thongs are attached to the soleby plugs which lock into holes in the sole;(f) Nonwaterproof footwear produced

TR 962682703 LARUTAN caneKAKI TIGAMENGOBATISARIAWAN, PANAS DALAM, SAKIT TENGGOROKAN,SUSAH BUANG AIR BESAR,++ Orang dewasa minurt 3 kali sehast 1/2 kaleng siempai 1 kaleng.Anakanak minum 3 kall sahar 1/4 katong samnpai 1/2 kintong.ealwah: Orang dawasa minum 1 kaliAngkanak minum 1 ail Bakentahan (ainsampal6 Khaniat den kogunean :The proparaton is a tractiqnal medicine which gives a coolingin body hezxiness, flu, gingivitis, sora throat, constipation.Recommended consumption :For treatment purpose ;

Orang dewsne minuen 3 kill seharl 1/2 kaleng sampal 1 kaleng.Angkanak minum 3 kali sehar 7/4 kaleng sarngal 1/2 kaleng.SparPenyedan Rasa Apel q.sBahanbahan kin sanypalSerttikat Halal MUI No, : O01 20035590705.consumption Komposisi :Gypsum Fibrosumiiii:For treatment purpose : Adults consume 1/2 oan 1 can 3 times daily,LAYANAN PELANGGAN / CUSTOMER GARE: PO BOX 1458 JKT 10014hasiat dan kegunaan:Cura PemakalanUntuk Penigqabatan :Iii) The preparation is a traditional madicine which givesw Hal. 3 dari

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."

This refers to Article 1 on Definitions, page31, paragraph 2 of the Syndicated Credit Facility Agreement No. 159(see Exhibit P1), which states as follows:"Scheduled Completion Date:means the date that Project Completion is required to occur pursuantto this Agreement, which date shall be not later than 31st (thirty first)day of December 1996 (one thousand nine hundred and ninety six) ,unless Majority Lenders otherwise agree in writing.As translated into Indonesian Language as follows:"Date of completion

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 SMG26.2/.28.failed to be used for the original purpose, which is to finance theproject construction in accordance with the budget.

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 warlesvery much between different types of footwear, from those covering the foot and the wholeleg, including the thigh (for example, fishermens boots), to these 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 area, no account being taken ofaccessories or reinforcements such as ankle patches, protective or ormamental

Berdasarkan General Explanatory Notes Chapter 64, pada alineapertama disebutkan 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.f.

Putusan Nomor 444/B/PK/Pjk/202064.01 Waterproof Footwear with outer soles and uppers of rubber orof plastics, the uppers of which are neither fixed to the sole norassembled by stitching, riveting, nailing, screwing, plugging orsimilar processes;64.02 Other footwear with outer soles and uppers of rubber orplastics;8.

memenuhi syarat kKedua karena pembuatannya dengan carainjection moulding, karena untuk masuk pos 64.02 harus memenuhisyarat pembuatannya dengan cara dijahit, dikeling, dipaku, disekrup,ditusuk atau dengan cara semacam itu;Bahwa pada penjelasan pos 64.02 pada halaman XIl 64021Explanatory Notes, Fifth Edition , Volume 3, dinyatakan: The Headingcovers, inter alia:(a) Ski boots consisting of several moulded parts hinged on rivets orsimilar devices;(b) Clogs without quarter or counter, the uppers of which

areproduced in one piece usually attached to the base or platform byriveting;(c) Slippers or mules without quarter or counter, the uppers of which,being produced in one piece or assembled other than by stitching,are attached to the sole by stitching;(d) Sandals consiting of straps across the instep and counter orheelstrap attached to the sole by any process;(e) Thongtype sandals in which the thongs are attached to the soleby plugs which lock into holes in the sole;(f) Nonwaterproof footwear produced

memenuhi syarat kedua karena pembuatannya dengancara injection moulding, karena untuk masuk pos 64.02 harusmemenuhi syarat pembuatannya dengan cara dijahit, dikeling,dipaku, disekrup, ditusuk atau dengan cara semacam itu.Bahwa pada penjelasan pos 64.02 pada halaman XII 64021Explanatory Notes, Fifth Edition, Volume 3, dinyatakan : TheHeading covers, inter alia:(a) Ski boots consisting of several moulded parts hinged onrivets or similar devices;(b) Clogs without quarter or counter, the uppers of which

(c) Slippers or mules without quarter or counter,the uppersof which, being produced in one piece or assembled otherthan by stitching, are attached to the sole by stitching;(d) Sandals consiting of straps across the instep and counteror heelstrap attached to the sole by any process;(e) Thongtype sandals in which the thongs are attached tothe sole by plugs which lock into holes in the sole;(f.

Putusan Nomor 1491/B/PK/Pjk/201911,12.13.14.pembuatannya dengan cara dijahit, dikeling, dipaku, disekrup, ditusukatau dengan cara semacam itu;Bahwa pada penjelasan pos 64.02 pada halaman XII 64021Explanatory Notes, Fifth Edition, Volume 3, dinyatakan: The Headingcovers, inter alia:(a) Skiboots consisting of several moulded parts hinged on rivets orsimilar devices;(b) Clogs without quarter or counter, the uppers of which are producedin one piece usually attached to the base or platform by riveting

;(c) Slippers or mules without quarter or counter, the uppers of which,being produced in one piece or assembled other than by stitching,are attached to the sole by stitching;(d) Sandals consiting of straps across the instep and counter orheelstrap attached to the sole by any process;(e) Thongtype sandals in which the thongs are attached to the sole byplugs which lock into holes in the sole;(f) Nonwaterproof footwear produced in one piece (for example,bathing slippers);Bahwa dengan Explanatory Notes

Bahwa adapun isi dari email yang dikirimkan oleh terdakwa kepada saksi LuluFuad Almusawa,SH dengan alamat lulu@permatamedia.com yang isi emailnyasebagai berikut :Dear Lulu,Thank you for your email belowPlease refer to my website (addres below) and the press section, which confirmsmy companies position in bali have featured in 5 or 6 articles over the past 18month. am also able to put you in touch with the shareholders of he Cangguclub.Furtheremore, since receiving your email below my Jakarta lawyers

, as well aslocal bali lawyers, have proceeded with both criminal charges, as well as a civilcourt case against Caroline Sandriany ang Gunawan Raharjo for defamation,fraud and theftparticularly in regard to the Nunia Boutique Hotel asset in which mycompany was a 50 percent partner.

Bahwa selanjutnya terdakwa mengirim email kepada saksi Lulu FuadAlmusawa,SH dengan alamat lulu@permatamedia.com yang isi emailnyasebagai berikut :Dear Lulu,Thank you for your email belowPlease refer to my website (addres below) and the press section, which confirmsmy companies position in bali have featured in 5 or 6 articles over the past 18month. am also able to put you in touch with the shareholders of he Cangguclub.Furtheremore, since receiving your email below my Jakarta lawyers, as well aslocal

bali lawyers, have proceeded with both criminal charges, as well as a civilcourt case against Caroline Sandriany ang Gunawan Raharjo for defamation,fraud and theftparticularly in regard to the Nunia Boutique Hotel asset in which mycompany was a 50 percent partner.

and the press section, whichconfirms my companies position in bali have featured in 5 or 6 articles overthe past 18 month. am also able to put you in touch with the shareholders ofhe Canggu club.Furtheremore, since receiving your email below my Jakarta lawyers, as wellas local bali lawyers, have proceeded with both criminal charges, as well as acivil court case against Caroline Sandriany ang Gunawan Raharjo fordefamation, fraud and theftparticularly in regard to the Nunia Boutique Hotelasset in which

However, such royalties may also be taxed in theContracting State in which they arise, and according to thelaws of that Contracting State, but if the recipient is thebeneficial owner of the royalties the tax so charged shall notexceed 10 percent of the gross amount of the royalties.3.

The provisions of paragraphs 1 and 2 shall not apply if thebeneficial owner of the royalties, being a resident of aContracting State, carries on business in the otherContracting State in which the royalties arise, through apermanent establishment situated therein, or perForms inthat other Contracting State independent personal servicesfrom a fixed base situated therein, and the right or propertyin respect of which the royalties are paid is effectivelyconnected with such permanent establishment or

Where, however, the person paying theroyalties, whether he is a resident of a Contracting State ornot, has in a Contracting State a permanent establishmentor a fixed base in connection with which the liability to paythe royalties was incurred, and such royalties are borne bysuch permanent establishment or fixed base, then suchroyalties shall be deemed to arise in the Contracting Statein which the permanent establishment or fixed base issituated.Where, by reason of a special relationship between thepayer

and the beneficial owner or between both of them andsome other person, the amount of the royalties, havingregard to the use, right or inFormation for which they arepaid, exceeds the amount which would have been agreedupon by the payer and the beneficial owner in the absenceof such relationship, the provisions of this Article shall applyonly to the lastmentioned amount.