OrbitaxUkraine State Fiscal Service Clarifies when a Distributor's Payments to a Software Copyright Holder are Subject to Royalty Withholding Tax under U.S. Tax Treaty
|Treaty Development|Ukraine-United States
In a Letter published on 19 July 2017 (Guidance Letter No. 722/6/99-99-01-02-02-15/IPK) Ukraine's State Fiscal Service ("SFS") discussed different arrangements between the software copyright holder and the software distributor and the extent to which each would qualify as a royalty under Article 12 of the Ukraine - United States treaty and be subject to a 10% wi…
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