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Ukraine Court Holds Funding Received by PE from Polish Parent Not Taxable in Ukraine

|Treaty Development|Ukraine-Poland
Ukraine-Poland

A decision of the Supreme Court of Ukraine dated 24 May 2019 was recently published concerning the treatment of funding received by a permanent establishment (PE) in Ukraine from its Polish parent. The case involved a PE that conducted market research for the sale of goods manufactured by the Parent, with no income aside from the Parent funding. While the PE determined that it had no taxable i…

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