For the purposes of determining the profits of the MOU, all expenses and deductions that would reasonably be attributable to PE and deductible if PE were an independent undertaking, and the profits of PE shall be determined as if it were a separate and distinct undertaking carrying out the same or similar activities under the same or similar conditions and acting independently with the undertaking, This is an MOU. The mere purchase of goods or goods by an MOU for the enterprise does not result in profits attributable to that MOU. The allocation of profits to the EP must be carried out annually according to the same method, unless there is a valid reason to the contrary. If the information available to the competent authority is insufficient, the provisions of the Agreement shall not affect the law of the Contracting State or the discretion of the competent authority. The first Singapore-Indonesia double taxation convention was concluded in 1990. . .