Ukraine's State Fiscal Service (SFS) recently published guidance letter No. 28476/6/99-99-15-02-02-15, which clarifies the deductibility of royalty payments to non-residents in the absence of a certificate of residence when such non-resident is registered in a jurisdiction included in the list of tax havens. According to the letter, such payments are non-deductible regardless of the presence of a certification of residence. Likewise, royalty payments to a non-resident not registered in a tax…