Ukraine's State Fiscal Service (SFS) recently published guidance letter No. 18373/10/26-15-14-06-04-29, which clarifies that taxation of royalties paid by a Ukraine resident to a UK resident. According to the letter, the standard withholding tax rate on royalties paid from a Ukraine to a non-resident is 15% under domestic law. However, under Article 12 (Royalties) of the 1993 income and capital tax treaty with the UK, the Ukrainian payer (tax agent) may apply an exemption, provided that:
- The…