Ukraine's State Fiscal Service (SFS) recently published a guidance letter on the eligibility of a Cyprus resident for treaty benefits on dividends received from a wholly-owned legal entity in Ukraine. Under the 2012 Cyprus-Ukraine tax treaty, a 5% withholding tax rate applies if the beneficial owner holds at least 20% of the paying company's capital or the beneficial owner has invested the equivalent of at least EUR 100,000 in the acquisition of shares or other rights in the paying company. O…