The tax authorities issued regulations PER-24/PJ/2010 and PER-25/PJ/2010 on 30 April 2010, which provide further clarification on the claim for treaty benefits as previously stipulated by regulations PER-61/PJ/2009 and PER-62/PJ/2009. Both of the new regulations apply retrospectively from 1 January 2010. PER-25/PJ/2010 provides the following clarification to the issue of "beneficial owner": -   The "beneficial owner" requirement is only imposed on non-residents where the tax treaty in question makes reference to the term. -   The phrase "active operations or business" shall be interpreted based on the taxpayer's actual situation, and factors such as costs incurred and efforts directly...