The Ukraine State Fiscal Service has recently published an individual consultation letter (1377/6/99-99-01-02-02-15/IPK) on the withholding tax treatment of dividends paid to a Lithuanian partnership. The letter clarifies that the benefit of the reduced withholding tax rate on dividends under the treaty may apply for dividends paid in favor of a partner, provided that the partner in the partnership is a legal entity formed and operated under the laws of Lithuania and is the actual beneficial owner of the dividend income. In this case, the tax agent may withhold tax by applying the beneficial treaty rate subject to standard conditions,...