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 solely for the purpose of gaining treaty benefits; -   where the legal form of transactions differs from the economic substance, for the sole purpose of obtaining treaty benefits; and -   where the recipient of the income is not the "beneficial...