Composition and Calculation of Deemed Dividends Revised

In an effort to encourage greater transparency and to provide legal certainty and fairness as regards the imposition of tax upon domestic taxpayers in relation to their capital participation in any foreign business entities which are not listed on stock exchanges (“ Non-Listed Foreign Business Entities ”), the Minister of Finance (“ Minister ”) recently issued Regulation No. 93/PMK.03/2019 (“ Amendment ”) as an amendment to Regulation of the Minister No. 107/PMK.03/2017 on the Determination of the Moment of Acquisition of Dividends and the Basis for Their Calculation by Domestic Taxpayers for Capital Participation in Foreign Business Entities Other Than Business Entities Selling Their Shares on Stock Exchanges [1] (“ Regulation 107/2017 ”). [2]