Indonesia's Ministry of Finance has issued Regulation 93/PMK.03/2019, which amends Regulation 107/PMK.03/2017 on deemed dividends from unlisted controlled foreign companies (CFCs). This includes amendments to the types of CFC income that may be treated as deemed dividends, as well as amendments to the calculation of the deemed dividend amount.
With respect to the type of CFC income, Regulation 93/PMK.03/2019 provides that instead of including all post-tax CFC income, deemed dividends will o…