Stamp Duty Stock transactions in Indonesia is subject to stamp

157 PT Telkom Indonesia Persero Tbk purposes, or investors who have their functional currency other than the U.S.Dollars, all of which may be subject to very diferent tax rules other than the summary below. Moreover, this summary does not address considerations relating to property tax and grants from the U.S.A federal sic states, locals, or non-U.S.A tax considerations. Each shareholder is advised to have consultation with their tax advisors concerning the U.S.A federal, states, locals and non-U.S.A incomes, and other tax considerations of their investment in ADSs or common stocks. For the purpose of this summary, “U.S.A shareholder” is a beneicial owner of ADSs or common stocks in which, for the U.S.A federal income tax purposes, i an individual who is a citizen or resident of the U.S.A, ii a company, or other entities treated as a company for federal income tax purposes, corporated in, established under the laws of the U.S.A or the state or the District of Columbia, iii any entity established or organized in or under the laws of another jurisdiction if it is treated as a domestic company in accordance with the tax laws, iv income from property that is included in gross revenues for federal income taxation purposes regardless of its sources, or v the trust A which the implementation is the subject of major supervision of U.S. courts and owned by one or more American citizen who have the authority to control all substantial decisions or B that has otherwise elected to be treated as U.S.A citizens according to the tax laws. If a partnership or other entities which treated as a “transparent tax” entity for the U.S.A tax purposes is the holder of ADSs or common stocks, therefore, tax treatment of a partner in a partnership or the stackholder in “transparent tax” entity generally depends on the status of the partners or shareholders and the activities of the partnership or “transparent tax “ entities. For federal income tax purposes, the U.S.A citizens who own ADSs will be treated as the owner who receives the beneits of Common Stocks which represented by ADSs.

1. Threshold Classiication of passive foreign investment Company “piap”

A non-U.S.A company, such as Telkom, will be treated as a PIAP for the U.S.A Federal income tax purposes, if 75 or more of its gross revenues consists of a speciic “passive” income or 50 or more of its assets are passive. Based on the Company’s revenues and assets in 2014, we strongly believe that the Company is not classiied as a PIAP. Because of the status of PIAP is determined by intensive facts made on annual basis, there is no guarantee that the Company is not or will not be classiied as a PIAP. The following discussion regarding “Dividends” and “Sales or Other Transfers of the ADSs or Common Stocks” are made on the basis that the Company will not be classiied as a PIAP for the U.S.A Federal income tax purposes.

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PT Telkom Indonesia Persero Tbk

2. Dividends Any distribution of cash dividends paid by the Company

out of earnings and proits as determined by the principles of the U.S.A Federal income tax, will be imposed with income tax on dividends and will be included in the gross income of the U.S.A Citizen Shareholders at the time it is received. In general, the dividend recipient that is not a Company will be subject to an income tax on dividends of a “qualiied foreign Company” with a maximum of the U.S.A Federal tax rate of 15, instead of the marginal tax rate which is applicable to an ordinary income, so long that they have fulilled the speciic period of ownership requirement. As a note, as of January 1, 2011, dividends from a qualiied foreign Company is treated as an ordinary income with a maximum tax rate of 39.6 applicable to dividends received by non-companies after the end of 2010. A non-U.S.A company other than PFIC, generally, will be treated as an eliglible foreign company i if eligible to get beneits in entirety from the U.S.A tax treaties and which is determined by the Financial Minister of the U.S.A to fulill the purpose of this provision and includes information exchange program or ii with respect to dividends paid in the form of shares or ADSs which is supported by such shares that are ready to be traded on a stock exchange established in the United States of America. Upon the completion of applicable tax treaty between the US and Indonesia, which has been determined by the Minister of Finance has fulilling this purpose and we believe that we are eligible to get beneit from the treaties. In addition, because the ADSs are listed on NYSE, an established securities market in the U.S.A, therefore, it is considered to be easily traded on the stock exchange. The amount of cash distributed in Rupiah shall equal with the U.S.Dollars value of the Rupiah at the date of receipt of the distribution, regardless of whether the amount is actually converted into the U.S.Dollars at that time. The proit or loss, if any, is recognized on the subsequent sale, conversion, or other disposition in Rupiah, and generally will be a source of regular income or loss. Generally, dividends received from the ADSs or common stocks are not qualify for deduction of dividends received by the company. Dividends will generally be regarded as income from foreign sources for credit purposes of the U.S. foreign tax. The U.S. shareholders may be eligible, subject to a number of complex limitations, to claim a foreign tax credit in respect with a foreign withholding tax imposed on dividends received because of ADSs or common stocks. The U.S shareholders who did not decided to claim a foreign tax credit for foreign taxes withheld, not to claim a deduction, for federal income tax purposes which in respect of the withheld, but only for a year in which the shareholders choose to do so for all credited foreign income taxes. 3. Sale or Transfer of ADSs or Common Stocks In general, shareholders who are United States nationals declare capital gains and losses arising from the sale or transfer of ADS or common stock, in the amount of the diference between the realization amount upon such transfer, with the tax base adjusted for the aforementioned shareholders of ADS or common stock. Capital gains or losses shall be long-term in nature, in the event that such ADS or common stock has in the possession of the shareholder for more than one year, and shall be a source of gains or losses for the US for the purposes of the US foreign tax credit.

4. Consequences of a PIAP In the event that the Company is classiied as a PIAP

within a certain iscal year, U.S. Shareholders are required to comply with special regulations that are generally aimed at reducing or eliminating the beneits of Federal U.S. income tax postponements, that may be gained by U.S. Shareholders from their investments in non- U.S. Companies that do not distribute all their gains on the current basis. In this regard, U.S. Shareholders may be subject to regular income tax fees over i gains recognized upon the sale of ADS or common stock and ii distribution surplus paid upon ADS or common stock in general, distributions that exceed 125 of the annual distribution average that we pay over the period of three prior iscal years. Furthermore, U.S. Shareholders shall be subject to interests on such gains or distribution surpluses. Aside from that, the maximum tarif of 15 of the Company’s dividends shall not be applied if the Company is to be considered as a PIAP.

5. Income Tax Reserves and Information Disclosure Requirements

U.S. income tax reserves and information disclosure requirements generally apply towards several payments made to certain non-cooperative shareholders. A tax- paying party shall be required to withhold its income tax