The Ukraine State Tax Service (STS) recently issued guidance letter 1150/IPK/99-00-21-02-02-06 concerning the tax obligations when a non-residents sales shares in a Ukraine resident company to another non-resident. The letter provides that such sales are generally subject to 15% withholding tax in Ukraine unless an applicable tax treaty provides otherwise. Where tax is to be withheld, the purchaser of the shares is required to register with the Ukraine tax authority prior to making payment fo…