Indonesian taxpayers are deemed to have control over non-listed foreign entities if they own at least 50% of ownership or if they own at least 50% of ownership collectively with other Indonesian taxpayers.
The ownership used to determine the CFC status is the ownership percentage at the end of the Indonesian taxpayer’s fiscal year, based on either the percentage of paid-up capital or the percentage of paid-up capital with voting rights.
CFC rules also apply to trust and other similar foreign entities.