In a Letter published on 19 July 2017 (Guidance Letter No. 722/6/99-99-01-02-02-15/IPK)  Ukraine's State Fiscal Service ("SFS")  discussed different arrangements between the software copyright holder and the software distributor and the extent to which each would qualify as a royalty under  Article 12 of the Ukraine - United States treaty and be subject to a 10% withholding tax: Distribution Rights only without the right to reproduce the program:  as there are no rights granted to the software copyright, but just to distribute copies of the software - whether as tangible media or electronically-- payments for the distribution rights alone do not constitute a royalty.  ...