Group 1 - The article discusses the importance of tax jurisdiction and the distinction between resident and non-resident taxpayers, emphasizing that resident taxpayers are taxed on worldwide income while non-resident taxpayers are taxed only on income sourced within the jurisdiction [1] - Chinese companies establishing subsidiaries in Indonesia are generally recognized as resident taxpayers in Indonesia, subject to independent taxation according to both international tax practices and local tax laws [2][3] - The article highlights that subsidiaries must operate independently and maintain separate accounting to prevent issues related to transfer pricing among related entities [3] Group 2 - There are circumstances under which a subsidiary may be recognized as a permanent establishment (PE) of the parent company in Indonesia, leading to different tax obligations [6][11] - Specific scenarios that may lead to a subsidiary being classified as a PE include the splitting of engineering contracts, mixed labor relationships, and the presence of non-independent agents [11][13][14] - The recognition of a PE is influenced by the nature of the business activities and the duration of operations, with a focus on the evolving standards in the digital economy that may redefine traditional notions of a fixed place of business [15]