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Ukraine Clarifies Beneficial Ownership and Withholding Tax on Royalties under Tax Treaty with Russia

|Treaty Development|Ukraine-Russia
Ukraine-Russia

Ukraine's State Fiscal Service (SFS) recently published Guidance Letter № 6047 / 6 / 99-99-19-02-02-15, which clarifies the tax treatment of royalties paid to a non-resident. The guidance specifically addresses royalty payments made from Ukraine to a Russian resident through an agent.

According to the letter, a Ukrainian withholding tax agent may only apply the reduced withholding tax rate (10…

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