OrbitaxOrbitax

Ukraine Supreme Administrative Court Holds Dividends Paid out of Income Generated Prior to Ownership Eligible for Treaty Benefits

|Treaty Development|Ukraine-Cyprus
Ukraine-Cyprus

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…

Continue Reading