Yordania (Jordan)
AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND THE GOVERNMENT OF THE HASHEMITE KINGDOM OF JORDAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Article 1 PERSONAL SCOPE This Agreement shall apply to persons who are residents of one or both of the Contacting States. Article 2 TAXES COVERED This Agreement shall apply to taxes on income imposed on behalf of each Contracting State or of its political subpisions or local authorities, irrespective of the manner in which they are levied. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property. The existing taxes to which the Agreement shall apply are: a in lndonesia: the income tax imposed under the Undang-undang Pajak Penghasilan 1984 (Law No. 7 of 1983 as amended.) (hereinafter referred to as Indonesian tax). b In Jordan: – the income tax; – the distribution tax; – the social service tax; (hereinafter referred to as Jordanian tax). The Agreement shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes, which have been made in their respective taxation laws. Article 3 GENERAL DEFINITIONS For the purposes of this Agreement, unless the context otherwise requires; a i the term “Indonesia” comprises the territory of the Republic of Indonesia as defined in its laws; ii the term “Jordan” means the territories of the Hashemite Kingdom of Jordan, the territorial waters of Jordan and the seabed and subsoil of the territorial waters, and includes any are extending beyond the limits of the territorial waters of Jordan, the seabed and subsoil of any such area, which has been or may hereafter be designated, under the laws of Jordan, in accordance with international law, as an are over which Jordan has sovereign rights for the purposes of exploring and exploiting the natural resources, whether living or non-living; b the term “person” includes an inpidual, a company and any other body of persons; c the term “company” means any body corporate or any entity which is treated as a body corporate for tax purposes; d the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; e term “International traffic” means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State; f the term “competent authority” means: i in Indonesia: the Minister of Finance or his authorised representative; ii in the case of Jordan: the Minister of Finance or his authorised representative; g the term “national” means: i any inpidual possessing the nationality of a Contracting State; ii any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State; h the term “fixed base” means a permanent place in which professional activities are exercised. As regards the application of the Agreement by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the laws of that State concerning the taxes to which the Agreement applies. Article 4 RESIDENT For the purposes of this Agreement, the term “resident of a Contracting State” means any persons who, under the laws of that State, is liable to tax therein by reason of this domicile, residence, place of management or any other criterion of similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State. Where by reason of the provisions of paragraph 1 an inpidual is a resident of both Contracting States, then his status shall be determined as follows: a he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (center of vital interests); b if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode; c if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident of the State of which he is a national; d if the status of resident cannot be determined according to sub-paragraphs a-c, the competent authorities of the Contracting States shall settle the question by mutual agreement. Where by reason of the provisions of paragraph 1 a person other than an inpidual is a resident of both Contracting States, the competent authorities of the States shall settle the question by mutual agreement. Article 5 PERMANENT ESTABLISHMENT For the purposes of this Agreement, the term “permanent establishment” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. The term permanent establishment shall include especially: a a place of management; b a branch; c an office; d a factory; e a workshop; f a warehouse or premises used as sales outlet; g a farm or plantation; h a mine, an oil of gas well, a quarry or other place of extraction of natural resources, drilling rig or working ship used for exploration or exploitation of natural resources. The term permanent
Vietnam (Vietnam)
AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND THE GOVERNMENT OF THE SOCIALIST REPUBLIC OF VIETNAM FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Article 1 PERSONAL SCOPE This Agreement shall apply to persons who are residents of one or both of the Contracting States. Article 2 TAXES COVERED This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political subpisions or local authorities, irrespective of the manner in which they are levied. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, [and] taxes on the total amounts of wages or salaries paid by enterprises.. The existing taxes to which the Agreement shall apply are: (a) in Indonesia: the income tax imposed under the Income Tax Law 1984 (Law no. 7 of 1983 as amended); (hereinafter referred to as “Indonesian tax”); (b) in Vietnam: (i) the personal income tax; (ii) the profit tax; and (iii) the profit remittance tax (hereinafter referred to as “Vietnamese tax”). The Agreement shall also apply to any identical or substantially similar taxes which are imposed after the date of signature of this Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws. Article 3 GENERAL DEFINITIONS For the purposes of this Agreement, unless the context otherwise requires: (a) the term “Indonesia” comprises the territory of the Republic of Indonesia as defined in its laws and the adjacent areas over which the Republic of Indonesia has sovereignty, sovereign rights or jurisdiction in accordance with the provisions of the United Nations Convention on the Law of the Sea, 1982; (b) the term “Vietnam” means the Socialist Republic of Vietnam; when used in a geographical sense, it means all its national territory, including its territorial sea and any area beyond and adjacent to its territorial sea, within which Vietnam by Vietnamese legislation and in accordance with international law, has sovereign rights or exploration for and exploitation of natural resources of the seabed and its subsoil and superjacent waters; (c) the terms “a Contracting State” and “the other Contracting State” mean Vietnam or Indonesia, as the context requires; (d) the term “person” includes an inpidual, a company and any other body of persons; (e) the term “company” means any body corporate or any entity which is treated as a body corporate for tax purposes; (f) the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; (g) the term “national” means: (i) any inpidual possessing the nationality of a Contracting State; (ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State; (h) the term “international traffic” means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State; and (i) the term “competent authority” means: (i) in the case of Indonesia, the Minister of Finance or his authorized representative; and (ii) in the case of Vietnam, the Minister of Finance or his authorized representative. As regards the application of the Agreement by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Agreement applies. Article 4 RESIDENT For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management, or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein. Where by reason of the provisions of paragraph 1 an inpidual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he does not have a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident of the State of which he is a national; (d) if he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement Where by reason of the provisions of paragraph 1 a person other than an inpidual is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its place of effective management is situated. Article 5 PERMANENT ESTABLISHMENT For the purposes of this Agreement, the term “permanent establishment” means a fixed place of business through which the business of the enterprise is wholly or partly carried on. The term “permanent establishment” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop;
Venezuela (Venezuela)
AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND THE GOVERNMENT OF THE REPUBLIC OF VENEZUELA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Article 1 PERSONAL SCOPE This Agreement shall apply to persons who are residents of one or both of the Contracting States. Article 2 TAXES COVERED This Agreement shall apply to taxes on income imposed on behalf of each Contracting State, irrespective of the manner in which they are levied. There shall be regarded as taxes on income all taxes imposed on total income or on elements of income, including taxes on gains from the alienation of movable or immovable property, [and] taxes on the total amounts of wages or salaries paid by enterprises. The existing taxes to which the Agreement shall apply are in particular: (a) in the case of Venezuela: the taxes on income and the business assets tax (hereinafter referred to as “Venezuelan tax”); (b) in the case of Indonesia: the income tax imposed under the Undang-undang Pajak Penghasilan 1984 (Law No. 7 of 1983 as amended) (hereinafter referred to as “Indonesian tax”). The Agreement shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. At the end of each year, the competent authorities of the Contracting States shall notify each other of relevant changes which have been made in their respective taxation laws. Article 3 GENERAL DEFINITIONS For the purposes of this Agreement, unless the context otherwise requires: (a) (i) the term “Venezuela” means the Republic of Venezuela; (ii) the term “Indonesia” comprises the territory of the Republic of Indonesia as defined in its laws and the adjacent areas over which the Republic of Indonesia has sovereignty, sovereign rights or jurisdiction in accordance with the provisions of the United Nations Convention on the Law of the Sea, 1982; (b) the term “person” includes an inpidual, a company and any other body of persons; (c) the term “company” means any body corporate or any entity which is treated as a body corporate for tax purposes; (d) the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; (e) the term “international traffic” means any transport by ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State; (f) the term “competent authority” means: (i) in the case of Venezuela, the Superintendent of the Integrated National Service of Tax Administration (Servicio Nacional Integrado de Administración Tributaria-SENIAT), its authorized representative or the authority which is designated by the Minister of Finance as a competent authority for the purposes of the Agreement; (ii) in the case of Indonesia, the Minister of Finance or his authorized representative; (g) the term “national” means: (i) any inpidual possessing the nationality of a Contracting State; (ii) any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State. As regards the application of the Agreement by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Agreement applies. Article 4 RESIDENT For the purpose of this Agreement, the term “resident of a Contracting State” means any person, who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of incorporation or any other criterion of a similar nature. In the case of Venezuela, the term includes any resident person or company subject to the Venezuelan territorial system of taxation. Where by reason of the provisions of paragraph 1 an inpidual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he does not have a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident of the State of which he is a national; (d) if he has a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. Where by reason of the provisions of paragraph 1 a person other than an inpidual is a resident of both Contracting States, the competent authorities of the States shall settle the question by mutual agreement. Article 5 PERMANENT ESTABLISHMENT For the purposes of this Agreement, the term “permanent establishment” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. The term “permanent establishment” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop, (f) a warehouse in relation to a person providing storage facilities for others; (g) a store or other sales outlet; (h) a farm or plantation; (i) a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used for exploration or exploitation of natural resources.
Uzbekistan (Uzbekistan)
AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND GOVERNMENT OF THE REPUBLIC OF UZBEKISTAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAKES ON INCOME (PROFITS) Article 1 PERSONAL SCOPE This Agreement shall apply to persons who are residents of one or both of the Contracting States. Article 2 TAXES COVERED This Agreement shall apply to taxes on income (profits) imposed on behalf of each Contracting State or local authorities, irrespective of the manner in which they are levied. There shall be regarded as taxes on income (profits) and all taxes imposed on total income or on elements of income including taxes on gains from the alienation of movable or immovable property, and taxes on the total amounts of wages or salaries paid by enterprises The existing taxes to which the Agreement shall apply are in particular : (a) in the case of the Republic of Uzbekistan: (i) the tax on income (profits) of enterprises, associations and organizations, and (ii) the inpidual income tax on the citizens of the Republic of Uzbekistan, foreign citizens and stateless persons (b) in the case of the Republic of Indonesia: the income tax imposed under the Undang-undang Pajak Penghasilan 1984 (Law no. 7 of 1983 as amended) (hereinafter referred to as “Indonesian tax”). The Agreement shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws. Article 3 GENERAL DEFINITIONS For the purposes of this Agreement, unless the context otherwise requires : (a) the term Indonesia means the territory of the Republic of Indonesia as defined in its laws ; (b) the term “Indonesia” means the territory of the Republic of Indonesia as defined in its laws; (c) the terms “Contracting State” and “the other Contracting State” mean Uzbekistan or Indonesia as the context requires; (d) the term “person” includes an inpidual, a company and any other body of persons; (e) the term “company” means any person that is a body corporate or any partnership, joint venture or other entity which is treated under the laws of the Contracting State from which it derives its status as such as a body corporate for tax purposes; (f) the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean respectively an enterprise carried on by a person who is a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; (g) the term “international traffic” means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State; (h) the term “competent authority” means, in the case of the Republic of Uzbekistan the Chairman of the State Tax Committee or his authorized representative, and in the case of the Republic of Indonesia the Minister of Finance or his authorized representative; (i) the term national means; (i) any inpidual possessing the nationality of a Contracting State; (ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State. As regards the application of the Agreement by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Agreement applies. Article 4 RESIDENT For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State. Where by reason of the provisions of paragraph 1 an inpidual is a resident of both Contracting States, then his status shall be determined as follows : (a) he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident of the State of which he is a national; (d) if each of the Contracting States considers him to be a resident of that State or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual Agreement. Where by reason of the provisions of paragraph 1 a person other than an inpidual is a resident of both Contracting States, the competent authorities of the State shall settle the question by mutual agreement. Article 5 PERMANENT ESTABLISHMENT For the purposes of this Agreement, the term “permanent establishment” means a fixed place of business through which the business of an enterprise of a Contracting State is wholly or partly carried on in the other Contracting State. The term permanent establishment includes especially : (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a farm or plantation; (g) a mine, an oil or gas well, a quarry
Uni Emirat Arab (United Arab Emirates
AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND THE GOVERNMENT OF THE UNITED ARAB EMIRATES FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME Article 1 PERSONAL SCOPE This Agreement shall apply to persons who are residents of one or both of the Contracting States. Article 2 TAXES COVERED This Agreement shall apply to taxes on income imposed on behalf of a Contracting State, or its political subpisions or local authorities irrespective of the manner in which they are levied There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from alienation of movable or immovable property. The existing taxes to which this Agreement shall apply [are]: (a) in the case of Indonesia : the income tax imposed under the Undang-undang Pajak Penghasilan 1984 (Law No. 7 of 1983 as amended) (income tax laws) (hereinafter referred to as Indonesian tax); (b) in the case of the United Arab Emirates : income tax, corporation tax (hereinafter referred to as U.A.E. tax). This Agreement shall also apply to any identical or substantially similar taxes which are imposed after the date of signature of this Agreement in addition to, or in place of, the existing taxes referred to in paragraph 2. The competent authorities of the Contracting States shall notify each other of any substantial changes which are made in their respective taxation laws within a reasonable period of time after such changes. Article 3 GENERAL DEFINITION For the purpose of this Agreement, unless the context otherwise requires : (a) the terms a “Contracting State” and “the other Contracting State” mean, as the context requires, the United Arab Emirates of the Republic of Indonesia; (b) the term “Indonesia” comprises the territory of the Republic of Indonesia as defined in its laws and the adjacent areas over which the Republic of Indonesia has sovereignty, sovereign rights or jurisdiction in accordance with the provisions of the United Nations Convention on the Law of the Sea, 1982; (c) the term “United Arab Emirates”, means the United Arab Emirates and, when used in [the] geographical sense, means its territory, including islands, territorial sea, and any other area in the sea or in the air within which the United Arab Emirates exercises under its law and in conformity with international law, sovereign rights or its jurisdiction; (d) the term “tax” means U.A.E. tax or Indonesian tax as the context requires; (e) the term “person” includes an inpidual, a company, or any other body of persons; (f) the term “company” means any body corporate or any entity which is treated as a body corporate for tax purposes; (g) the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean, respectively, an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; (h) the term “national” means all inpiduals possessing the nationality of a Contracting State and all legal persons, partnerships and associations deriving their status as such from the law in force in a Contracting State. The term “international traffic” means any transport by ships or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State. The term “competent authority” means : (i) in case of the Republic Indonesia, the Minister of Finance or his authorised representative; and (ii) in the case of U.A.E., the Minister of Finance and Industry or his authorised representative. In the application of this Agreement by either of the Contracting States, any term not defined therein shall — unless the context otherwise requires — have the meaning which it has under the laws of that State concerning the taxes to which the Agreement applies. Article 4 RESIDENT For the purposes of this Agreement, the term “resident of a Contracting State” means a person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature. Where by reason of the provisions of paragraph 1 an inpidual is deemed to be a resident of both Contracting States, then his status shall be defined as follows: (i) he shall be deemed to be a resident of the State in which he has a permanent home available to him. If he has a permanent home available to him in both Contracting States, he shall be deemed to be a resident of the Contracting State with which his personal and economic relations are closer (centre of vital interests); (ii) if the Contracting State in which he has his centre of vital interests cannot be determined, or if he does not have a permanent home available to him in either Contracting State, he shall be deemed to be a resident of the Contracting State in which he has an habitual abode; (iii) if he has an habitual abode in both Contracting States or in neither of them, he shall be deemed to be a resident of the Contracting State of which he is a national; (iv) if he is a national of both Contracting States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. Where by reason of the provisions of paragraph one a person other than an inpidual is a resident of both Contracting States then it shall be deemed to be a resident of the State in which its place of effective management is situated. Article 5 PERMANENT ESTABLISHMENT For the purposes of this Agreement, the term “permanent establishment” means a fixed place of business in which the business of an enterprise is wholly or partly carried on. The term “permanent establishment” shall include specifically: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a mine,
Ukraina (Ukraine)
AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDONESIA AND THE GOVERNMENT OF UKRAINE FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL Article 1 PERSONAL SCOPE this Agreement shall apply to persons who are residents of one or both of the Contracting States. Article 2 TAXES COVERED This Agreement shall apply to taxes on income imposed on behalf of each Contracting State or of its political subpisions or local authorities, irrespective of the manner in which they are levied. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property. The existing taxes to which the Agreement shall apply are: (a) in Indonesia: the income tax imposed under the Undang-undang Pajak Penghasilan 1984 (Law no. 7 of 1983 as amended) (hereinafter referred to as “Indonesian tax”); (b) in Ukraine : (i) the tax on profit of enterprises; and (ii) the income tax on citizens. (hereinafter referred to as Ukrainian tax) The Agreement shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws. Article 3 GENERAL DEFINITIONS For the purposes of this Agreement, unless the context otherwise requires : (a) (i) the term “Indonesia” comprises the territory of the Republic of Indonesia as defined in its laws and the adjacent areas over which the Republic of Indonesia has sovereignty, sovereign rights or jurisdiction in accordance with international law; (ii) the term “Ukraine”, when used in [the] geographical sense, means the territory of Ukraine, its continental shelf and its exclusive (maritime) economic zone, including any area outside the territorial sea of Ukraine which in accordance with international law has been or may hereafter be designated as an area within which the rights of Ukraine with respect to the sea bed and sub-soil and their natural resources may be exercised; (b) the terms “a Contracting State” and “the other Contracting State” mean Ukraine or Indonesia, as the context requires; (c) the term “person” includes an inpidual, a company and any other body of persons; (d) the term “company” means any body corporate or any entity which is treated as a body corporate for the tax purposes; (e) the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean respectively an enterprise carried on by a resident of Contracting State and an enterprise carried on by a resident of the other Contracting State; (f) the term “international traffic” means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State; (g) the term competent authority means : (i) in Indonesia, the Minister of Finance or his authorized representative; (ii) in Ukraine, the Ministry of Finance, or its authorized representative; (h) the term “national” means : (i) any inpidual possessing the nationality of a Contracting State; (ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State. As regards the application of the Agreement by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Agreement applies. Article 4 RESIDENT For the purpose of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of registration or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State. Where by reason of the provisions of paragraph 1 an inpidual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode; (c) if he has an habitual abode in both Contracting States or in neither of them, he shall be deemed to be a resident of the Contracting State of which he is a national; (d) if he is a national of both States or neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. Where by reason of the provisions of paragraph 1 a person other than an inpidual is a resident of both Contracting States, then it shall be deemed to be a resident of the Contracting State in which it is incorporated. Article 5 PERMANENT ESTABLISHMENT For the purposes of this Agreement, the term “permanent establishment” means a fixed place of business through which the business of an enterprise is wholly or partly carried on. The term “permanent establishment” includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; (f) a warehouse or premises used as sales outlet; (g) a farm or plantation; (h) a mine, an oil or gas well, a quarry or any