On 5 November 2009, the tax office issued tax regulations PER-61/PJ/2009 and PER-62/PJ/2009 on the availability and claim for tax treaty benefits, effective 1 January 2010.
PER-62/PJ/2009 introduces anti-abuse provisions in relation to tax treaties and stipulates that treaty relief is not available in the following situations:
| - | where transactions lack economic substance and which are structured s… |