The Ukraine State Fiscal Service recently published an individual consultation concerning the taxation of income derived by an Austrian resident's income from the provision of freight forwarding services to a Ukraine resident. The letter notes that income derived from Ukraine is generally subject to 15% withholding tax unless there is an applicable tax treaty, in which case the provision of the treaty will apply. With respect to income from freight forward services, the 1997 Austria-Ukraine tax treaty contains no specific provisions, therefore Article 7 (Business Profits) applies. As such, the letter clarifies that income from freight forwarding services derived by...