OrbitaxRevised interpretation of "beneficial ownership" under tax treaties
|Treaty Development|Indonesia
The tax authorities issued circular SE-03/PJ.03/2008 on 22 August 2008 on their interpretation of the phrase "beneficial ownership" for tax treaty purposes. The issuance of this circular revokes circular SE-04/PJ.34/2005 on the same matter.
Both circulars provide that the "beneficial owner" is the real owner of income in the form of dividend, interest and/or royalty…
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