The leniency is puzzling. Indonesia could levy a 25% tariff on offshore funds, and their owners would still come out ahead. Nicholas Shaxson of the Tax Justice Network deems it “very likely that powerful people in Indonesia have engineered this to make sure they’re not exposed and not subject to penalties.” But expediency is another possible explanation: Mr Brodjonegoro says that if the government waits for the CRS to take effect, “The benefit in terms of tax revenue will only start in 2019, the end of this administration.”