pengenaan PPh pasal 26 seorang atlet yang dikontrak di Indonesia

Article 17
ARTISTES AND ATHLETES

1.

Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as an athlete, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State.
2.

Where income in respect of personal activities referred to in paragraph 1 accrues not to the entertainer or an athlete himself but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised.
3. The provisions of paragraphs 1 and 2 shall not apply:
(a)

to income derived from activities performed in a Contracting State by entertainers or athletes if the visit to that Contracting State is substantially supported by public funds of the other Contracting State, or by those of any political subdivision, local authority or statutory body thereof;
(b)

to income derived in a Contracting State by a non-profit organization of the other Contracting State in respect of such activities, provided that such organization is substantially supported by public funds of that other State, or by those of any political subdivision, local authority or statutory body thereof.

Tarrifnya 20%.

Pengaruhnya hanya untuk klausul ayat (3) saja.

Jika Atlet Thailand ikut perlombaan disini dan bisa memberikan CoD, maka sesuai ketentuan hak pemajakan ada di Indonesia, begitupun sebaliknya.