Ukraine Clarifies Application of Beneficial Tax Treaty Rates on Syndicated Loan Interest

The Ukraine State Fiscal Service recently published an individual tax consultation that clarifies that application of beneficial tax treatment (reduced rate or exemption) provided under tax treaties between Ukraine and relevant jurisdictions on interest paid in relation to a syndicated loan. The ability to apply treaty benefits on such interest was introduced as part of the tax reform for 2018. The letter clarifies that in order to apply beneficial treatment where the beneficiaries are locate…