The Ukraine State Fiscal Service has recently published an individual consultation on the validity of a certificate of residence for the purpose of applying treaty benefits. The consultation letter notes that for the beneficial provisions of a treaty to apply (reduced rate or exemption) the non-resident recipient of income must be the beneficial owner and provide a certificate of residence confirming its resident in the treaty partner jurisdictions, as well as any other documentation that may be prescribed in the repeal treaty. With regard to the certificate of residence, a treaty benefit may be applied at source in the current...