The Ukrainian State Fiscal Service (SFS) has released a guidance letter analyzing the tax consequences from the sale of shares in a Ukrainian resident legal entity by a resident of Austria. Guidance Letter 3348/IPK/99-00-05-05-02-06 (dated August 13) was released in response to an inquiry by a Ukrainian resident legal entity that intends to acquire shares that an Austrian legal entity holds in another Ukrainian resident legal entity. The capital of the legal entity in which the shares are held was formed from funds and immovable property located in Ukraine. The taxpayer wanted to know if it has to withhold the...