On 20 August 2012, the Ukraine Tax Service issued the clarification letter No. 1151/0/71-12/12-1017 regarding the application of the China (People's Rep.) - Ukraine Income and Capital Tax Treaty (1995). For the purposes of the treaty application, the term "China" does not cover territories with a special legal regime having an independent tax system and not covered by the Chinese tax legislation, such as Hong Kong, Macao and Taiwan.