On September 16, 2020, a bill of amendments to the income tax laws was published. The most important issue regulated by this bill is the inclusion of limited partnerships and some general partnerships into the circle of CIT taxpayers.
According to the tax authorities, yes. The contract for ongoing agency services, which is a commercial agency contract, is included in the list of intangible services subject to the limitation as to the amount of tax deductible costs on under Art. 15e (1) of the CIT Act - as stated by the Head of the National Revenue Information Service in the private tax ruling of June 19, 2020 (case no. 0111-KDIB1-3.4010.191.2020.2.JKT).