TAXATION continued 2004 12 Full Audited Financial Statements w Notes

PT BANK MANDIRI PERSERO TBK. AND SUBSIDIARIES NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS December 31, 2004 and 2003, and April 30, 2003 Expressed in millions of Rupiah, unless otherwise stated 95

27. TAXATION continued

Tax Decisions and Tax Assessments continued Based on the approval from the Minister of Finance through Decision No. S-206MK.012003 and the approval from the Directorate General of Taxation on the results of the fixed assets revaluation, Bank Mandiri is entitled to receive the transfer of tax losses from the merged banks and is able to utilize the tax losses as compensation against future taxable income. The amount of tax losses transferred to Bank Mandiri is Rp31,944,418. The transfer of tax losses has been taken into account by the Tax Office when re-assessing Bank Mandiri’s tax liabilities from 1999 to 2002, and such losses have been utilized to compensate the tax due on the increment arising from the revaluation of premises and equipment of the merged banks. On June 18, 2003, the Directorate General of Taxation issued Decision Letter No. KEP-093WPJ.07KP.01092003, which involved the official rectification of Decision Letter No. 001274069905101 dated November 20, 2001 adjusting the amount of the tax loss carried forward that can be against future taxable income by Rp13,659,210. Consequently, the amount of tax losses that can be against future taxable income became Rp8,234,516 for the year ended December 31, 1999. On June 20, 2003, the Directorate General of Taxation issued Decision Letter No. KEP-236WPJ.07BD.032003, which involves the “official rectification” of Decision Letter No. KEP-106WPJ.07BD.032003 dated March 14, 2003 regarding the taxpayer’s objection in relation to corporate income tax assessment SKPKB No. 000282060005102 dated July 5, 2002 for fiscal year 2000 which increased the taxable income for 2000 by Rp15,506,709 to become Rp28,236,332. Such taxable income had been compensated by the tax loss carried forward, therefore, the corporate income tax liability for the year 2000 was RpNil. On June 23, 2003, the Directorate General of Taxation issued tax decision letter No. 00005506010512003, increasing the taxable income for 2001 by Rp2,342,573 to become Rp6,746,964. The letter confirmed that Bank Mandiri has no corporate income tax liability for 2001 due to utilization of tax losses. On June 23, 2003, the Directorate General of Taxation issued tax decision letter No. 00001406020512003, adjusting the tax loss for 2002 by Rp7,659,860 to become taxable income for 2002 of Rp1,288,881. The letter confirmed that Bank Mandiri has no corporate income tax liability for 2002 due to utilization of tax losses. On October 29, 2003, Bank Mandiri received tax assessment letters dated October 24, 2003 regarding BDN tax audits for the period of January 1, 1999 up to July 31, 1999. Based on the assessment letters, BDN had tax underpayments amounting to Rp717,229 which consisted of income tax article 21 of Rp172,378, income tax article 23 of Rp301, value added tax of Rp1,501, income tax article 4 2 final of Rp542,846 and a value added tax collection letter for an amount of Rp203. On January 13, 2004, the Bank submitted an objection letter to the tax office regarding such tax assessment letters and the Director General of Taxation approved most of the Bank’s objections by issuing tax decision letters as follows: i. Tax decision letter dated August 9, 2004 revised the income tax article 23 assessment from Rp301 to Rp2. The Bank agreed with such decision, and accordingly has paid such amount. ii. Tax decision letter dated August 24, 2004 revised the value added tax assessment from Rp1,501 to Rp1,062. The Bank filed an appeal against such decision to the tax court on November 11, 2004. PT BANK MANDIRI PERSERO TBK. AND SUBSIDIARIES NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS December 31, 2004 and 2003, and April 30, 2003 Expressed in millions of Rupiah, unless otherwise stated 96

27. TAXATION continued