Deferred tax assetsliabilities continued Administration Tax assessment letter

220 cde IABlE, STrong, EFFICIEnT PT ADARO ENERGY Tbk AND SUBSIDIARIES Schedule 560 NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 31 DECEMBER 2013 AND 2012 Expressed in thousands of f S Dollars, unless otherwise stated

34. TAXATION continued

e. Deferred tax assetsliabilities continued

Due to the fact that several subsidiaries are in a loss position and only function as head offices, there is a limitation on the future use of tax losses carried forward and also uncertainty as to whether the deferred tax assets will be realised. Thus, a portion of the deferred tax assets relating to tax losses carried forward has not been recognised in these consolidated financial statements. All of the deferred tax assets are expected to be recovered after more than 12 months. The analysis of deferred tax liabilities is as follows: 2013 2012 Deferred tax liabilities to be recovered within 12 months 22,628 25,036 Deferred tax liabilities to be recovered after 12 months 626,132 576,053 648,760 601,089

f. Administration

Under the taxation laws of Indonesia, companies within the Group which are domiciled in Indonesia calculate and pay tax on the basis of self assessment. The Directorate General of Tax “DGT” may assess or amend taxes within ten years of the time the tax becomes due, or until the end of 2013, whichever is earlier. There are new rules applicable to the fiscal year 2008 and subsequent years stipulating that the DGT may assess or amend taxes within five years of the date the tax becomes due.

g. Tax assessment letter

Management of SIS disagreed with the tax assessments of corporate income tax and income tax Article 23 that were received in 2008 and therefore filed objection letters with the DGT against the tax assessment amounting to Rp 3,421 million. On 21 April 2009, the DGT accepted the objection on income tax article 23 of Rp 142 million and rejected the objection to corporate income tax of Rp 3,279 million. On 3 June 2009, SIS filed an appeal against the rejection amounting to Rp 3,279 million. On 27 June 2011, the tax court issued a decision to partially accept the appeal from SIS, amounting to Rp 2,397 million. On 8 December 2011, the DGT requested a civil review of the decision of the tax court. As of the date of these consolidated financial statements, there has been no result of the civil review. As at the date of these consolidated financial statements, the Company is being audited by the DGT for all taxes for the fiscal year 2012, Adaro for all taxes for the fiscal years 2011 and 2012, SIS for corporate income tax for the fiscal years 2009, 2010 and 2012, Viscaya for all taxes for the fiscal year 2009, AEI for all taxes for the fiscal year 2012, ATA for all taxes for the fiscal year 2012, DSM for all taxes for the fiscal year 2012, JPI for VAT for the fiscal years 2010, 2011 and 2012 and IBT for corporate income tax for the fiscal year 2012. The Company, Adaro, SIS, Viscaya, AEI, ATA, DSM, JPI and IBT have not yet received the tax audit results. Management is of the opinion that the tax audit results will not have a material impact on the Group’s consolidated financial position and cash flow. g u r p r o F Il E o u r M E SSA g E S o u r B u S In E S S o u r pE o pl E o u r g o v Ern A n C E o ur C o M M un IT IE S o u r I n v E S T o r S o u r F In An C E S h DAro EnErgy 2013 AnnuAl rEporT 221 PT ADARO ENERGY Tbk AND SUBSIDIARIES Schedule 561 NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 31 DECEMBER 2013 AND 2012 Expressed in thousands of i S Dollars, unless otherwise stated

35. TRANSACTIONS AND BALANCES WITH RELATED PARTIES

a. Nature of relationships