Menurut pendapat saya,
atas rental barang dari UK yg ditempatkan di Indonesia (pasti melebihi time test)…
diberlakukan seperti royalty.. sehingga terutang PPh Pasal 26.

Article 12 (Royalties) dengan china
1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State.
2. The rate of tax imposed by one of Contracting States on royalties derived from sources within that Contracting State and beneficiary owned by resident of the other Contracting State shall not exceed 10 percent of the gross amount of the royalties.
3. The term "royalties" as used in this Article means payments, whether periodical or not, and in whatever form or name or nomenclature to the extent to which they are made as consideration for:
b. the use of, or the right to use, any industrial, commercial or scientific equipment; or