Ukraine Supreme Administrative Court Holds Dividends Paid out of Income Generated Prior to Ownership Eligible for Treaty Benefits
The Ukraine Supreme Administrative Court has recently issued a decision concerning whether a foreign company that acquired a Ukrainian company is eligible for treaty benefits on dividends received if paid out of income generated prior to the acquisition. The case involved Sanitas, a private Ukrainian enterprise acquired in 2012 (100%), by Cyprus-based Rysio Holdings Limited, which was formed in…
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