Ukraine Clarifies Requirements for Treaty Benefits for Interest Payments Made Through an Intermediary

The Ukraine State Fiscal Service (SFS) recently issued guidance letter 4960/IPK/99-00-05-05-02-06 regarding the requirements for claiming tax treaty benefits where interest payments are made through an intermediary in a treaty country to a beneficial owner is another treaty country. The letter is in response to a query from a Ukraine resident entity paying interest to a Singapore resident entity for financing under a loan agreement that was funded by a loan obtained by the Singapore entity fr…