In determining such adjustment, due regard shall be had to the other provisions of the Agreement and the competent authorities of the Contracting States shall, if necessary, consult each other.ДЄ Contracting State shall not change the profits of an enterprise in the circumstances referred to in paragraph 2 after the expiry of the time limits provided in its tax laws. Where a Contracting State includes in the profits of an enterprise of that Contracting State - and taxes accordingly - profits on which an enterprise of the other Contracting State has been charged to tax in that other Contracting State, and the profits so included are profits which would have accrued to the enterprise of the first-mentioned Contracting State if the conditions made between the two enterprises had been those which would have been made between independent enterprises, then that other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits. Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.ДЇor the purposes of paragraphs 1 to 5, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. The method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the business of the permanent establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. The cutting and collection of income tax is in accordance with the provisions of taxation Income Tax Law number 36 Year 2008.Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment. The conclusion of the research on the purchase of goods with funds from state spending or shopping areas subject to Income Tax Article 22 amounting to 1.5% of the purchase price already have a taxpayer identification number (NPWP), Cutting of income tax article 23 for rent and other income in connection with the use of property amounting to 2% from total gross, construction service can be charged income tax based on article 4 paragraph 2 which is final. The analysis method used is descriptive method. Income tax (PPh) of Article 22 for the procurement of goods at the Ministry, income tax (PPh) of Article 23 for rent and other income in connection with the use of property, and income Tax (PPh) of Article 4 paragraph (2) for construction services. The purpose of this study was to determine the procedure for the cutting and collection of income tax. Tax is a contribution collected by the state from the central government and regional governments based on the Law, the cutting and collection of income tax for expenses derived from the State Budget by the treasurer of the Central Government and the Regions.

Pengertian pph 23