Recently, the State Tax Service made available clarification Letter No.12744/0/71-12/12-1017 which was issued on 27 December 2012. The letter provides general recommendations for the application of tax treaties concluded by Ukraine. The main provisions are summarized below: -   extensive commentaries are provided that are generally in line with the Commentaries of the OECD Model. The commentaries provided by the State Tax Service also include the interpretation of specific articles of the tax treaties concluded by Ukraine; -   recommendations regarding the interpretation of the permanent establishment concept; -   guidelines for the application of the articles regarding dividends, interest...