The Indonesian Ministry of Finance issued a new regulation on 27 July 2017 concerning deemed dividends from unlisted controlled foreign companies (CFCs), which updates and replaces Regulation 256/PMK.03/2008. The new regulation provides that a foreign company, other than a company listed on a stock exchange, is considered a CFC where at the end of the Indonesian shareholder's tax year, the shareholder:
- Holds a capital participation of at least 50% in the total paid-up shares of the foreign c…