Ukraine Clarifies Taxation of Non-Resident Income Resulting from a Reduction in Capital

Ukraine's State Fiscal Service has published guidance letter 521/6/99-00-07-02-02-15/IPK of 1 October 2019 which clarifies the taxation of income (return of investment) received by a non-resident as a result of a reduction in the authorized capital of foreign-invested enterprise resident in Ukraine. The letter clarifies that such income will be exempt from withholding tax to the extent that it does not exceed the amount of investment made by the non-resident in the corporate rights of the for…