On 3 October 2012, the Government issued a Decree to provide guidance for the grant of benefits under a tax treaty. To be eligible for the reduced withholding tax rate under an applicable treaty, taxpayers must submit a certificate of residence issued by the tax authorities of the other contracting (Residence) state. Unless the application of a tax treaty is disputed or unless such a certificate is submitted by the taxpayer, tax must be withheld according to the applicable domestic rates. The Government will provide further details on this new procedure in a subsequent Decree