[ABSTRAK
Tesis ini menganalisis dampak PER-24/PJ/2010 terhadap kepastian hukum danapakah persyaratan administrasi PER-24/PJ/2010 ini telah memenuhi rasakeadilan dan didasari ?good faith? sesuai pasal 31 ayat 1 Vienna Convention onthe Law of Tax Treaties (VCLT) dan OECD Model. Hasilnya PER-24/PJ/2010memberikan panduan administratif pemanfaatan Persetujuan Penghindaran PajakBerganda di Indonesia, namun persyaratan administratif yang diatur di dalamnyadapat menghalangi pemanfaatan tax treaty oleh Wajib Pajak Luar Negeri diIndonesia sehingga ?good faith? dalam pasal 31 VCLT tidak dapat terpenuhi.Proses pengadaan Surat Keterangan Domisili (SKD) memakan waktu karenaberhubungan dengan otoritas pajak negara lain. PER-24/PJ/2010 hendaknyadirevisi dengan menambahkan sanksi administrasi bagi yang tidak melampirkanSKD sesuai batas waktu yang dipersyaratkan.

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ABSTRACT,br>This thesis analyzes the impact of Regulation No. PER-24/PJ/2010 on the legalcertainty and services to tax payers and whether or not the administrativerequirements of PER-24/PJ/2010 have fulfilled the principles of legal certainty,fulfilling the sense of fairness and are based on ?good faith? pursuant to article 31of Vienna Convention on the Law of Tax Treaties (VCLT) and OECD Model.The result are PER-24/PJ/2010 provides an administrative guideline to theutilization of Tax Treaty in Indonesia. However, the administrative requirementsof PER-24/PJ/2010 may hamper the utilization of tax treaty by foreign tax payersin Indonesia, so that the definition of ?good faith? as referred to in article 31VCLT cannot be fulfilled. The process of procurement of Certificate of Domicile(COD) takes time since it relates with taxation authorities of other countries. PER-24/PJ/2010 should be revised by adding administrative penalty for those that failto attach COD according to the time limit as required;This thesis analyzes the impact of Regulation No. PER-24/PJ/2010 on the legalcertainty and services to tax payers and whether or not the administrativerequirements of PER-24/PJ/2010 have fulfilled the principles of legal certainty,fulfilling the sense of fairness and are based on ?good faith? pursuant to article 31of Vienna Convention on the Law of Tax Treaties (VCLT) and OECD Model.The result are PER-24/PJ/2010 provides an administrative guideline to theutilization of Tax Treaty in Indonesia. However, the administrative requirementsof PER-24/PJ/2010 may hamper the utilization of tax treaty by foreign tax payersin Indonesia, so that the definition of ?good faith? as referred to in article 31VCLT cannot be fulfilled. The process of procurement of Certificate of Domicile(COD) takes time since it relates with taxation authorities of other countries. PER-24/PJ/2010 should be revised by adding administrative penalty for those that failto attach COD according to the time limit as required;This thesis analyzes the impact of Regulation No. PER-24/PJ/2010 on the legalcertainty and services to tax payers and whether or not the administrativerequirements of PER-24/PJ/2010 have fulfilled the principles of legal certainty,fulfilling the sense of fairness and are based on “good faith” pursuant to article 31of Vienna Convention on the Law of Tax Treaties (VCLT) and OECD Model.The result are PER-24/PJ/2010 provides an administrative guideline to theutilization of Tax Treaty in Indonesia. However, the administrative requirementsof PER-24/PJ/2010 may hamper the utilization of tax treaty by foreign tax payersin Indonesia, so that the definition of “good faith” as referred to in article 31VCLT cannot be fulfilled. The process of procurement of Certificate of Domicile(COD) takes time since it relates with taxation authorities of other countries. PER-24/PJ/2010 should be revised by adding administrative penalty for those that failto attach COD according to the time limit as required, This thesis analyzes the impact of Regulation No. PER-24/PJ/2010 on the legalcertainty and services to tax payers and whether or not the administrativerequirements of PER-24/PJ/2010 have fulfilled the principles of legal certainty,fulfilling the sense of fairness and are based on “good faith” pursuant to article 31of Vienna Convention on the Law of Tax Treaties (VCLT) and OECD Model.The result are PER-24/PJ/2010 provides an administrative guideline to theutilization of Tax Treaty in Indonesia. However, the administrative requirementsof PER-24/PJ/2010 may hamper the utilization of tax treaty by foreign tax payersin Indonesia, so that the definition of “good faith” as referred to in article 31VCLT cannot be fulfilled. The process of procurement of Certificate of Domicile(COD) takes time since it relates with taxation authorities of other countries. PER-24/PJ/2010 should be revised by adding administrative penalty for those that failto attach COD according to the time limit as required]