The Ukraine State Tax Service (STS) recently issued guidance letter 2712/IPK/ 99-00-21-02-02-06 concerning the country's new controlled foreign company (CFC) rules that are coming into force on 1 January 2022. The letter concerns the possible exemption from the inclusion of CFC profit in taxable income that applies if the following conditions are met:

• there is a valid income tax treaty or tax …