Ukraine Supreme Court Holds Limits on the Deductibility of Royalties is Counter to the Tax Treaty with the U.S.
The Ukraine Supreme Court recently issued a decision concerning whether the general domestic rule limiting the deduction of royalties paid to non-residents can apply in light of the non-discrimination provisions of the 1994 income and capital tax treaty with the United States. The case involved the payment of royalties by a Ukraine payer to a U.S. resident, which the Ukraine tax authorities sou…
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