The Ukraine State Fiscal Service recently published a guidance letter concerning the taxation of the income of a Hong Kong resident sourced from Ukraine in relation to Ukraine's tax treaty with China and the need for residence certification. The letter notes that the tax treaty with China applies to all the territory of the People's Republic of China, including its territorial sea, where Chinese legislation on taxation applies. As such, the treaty does not apply to territories with a separate tax system, including Hong Kong, Macao, and Taiwan, in particular. Based on this, a Hong Kong resident will be taxed...