The Ukrainian State Tax Service recently issued Public Guidance Letter 9033/7/99-99-10-02-02-17, which clarifies the determination of beneficial ownership of income for the purpose of claiming tax treaty benefits. According to the letter, when a non-resident taxpayer or tax agent is resident in a country with which Ukraine has entered into a tax treaty, the non-resident may only be considered a beneficial owner and entitled to an exemption or reduced tax rate established by the tax treaty whe…