Interpretation of "beneficial owner" under tax treaties

Additional details regarding the Director-General of Taxation's circular letter SE-04/PJ.34/2005 dated 7 July 2005, in which guidance is given on how the term "beneficial owner" should be interpreted under tax treaties entered into by Indonesia, are available. A foreign company that claims treaty benefits is required to present its certificate of beneficial ownership in addition to its certificate of residence. The criteria under which a foreign company that received d…