The Ukraine State Fiscal Service recently issued a guidance letter concerning the tax treatment of gains from the alienation of shares in a resident company by a non-resident when sold to another resident company. The letter provides that under domestic law, such sales are generally subject to 15% withholding tax in Ukraine, with the Ukraine resident buyer required to act as the withholding tax agent. The taxable income is the positive difference between the income received from the sale of the shares and any duly documented expenses incurred by the non-resident in its initial acquisition (i.e., the actual capital gain)....