Following the ratification of the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent BEPS in 2019, President Joko Widodo has issued Presidential Regulation Number 63 of 2024 (“PR-63”), which updates the reservations in the previous Presidential Regulation Number 77 of 2019 (“PR-77”).

These new reservations have expanded the list of ratified parties covered by the convention to 13 (thirteen) countries, namely Austria, Belarus, Germany, Jordan, Kuwait, Mongolia, Morocco, Papua New Guinea, Singapore, Sri Lanka, Tunisia, Ukraine, and the United Arab Emirates.

The BEPS Multilateral Instrument allows governments to modify existing bilateral tax treaties in a synchronized manner to implement the tax treaty measures. Therefore, please be aware of these updates when applying the articles of the relevant tax treaties. This new Presidential Regulation became effective on 13 June 2024.