A decision of the Supreme Court of Ukraine dated 24 May 2019 was recently published concerning the treatment of funding received by a permanent establishment (PE) in Ukraine from its Polish parent. The case involved a PE that conducted market research for the sale of goods manufactured by the Parent, with no income aside from the Parent funding. While the PE determined that it had no taxable income in Ukraine, as it had derived no income from Ukraine, the Ukrainian tax authorities determined that the funding from the Polish parent should be treated as taxable income in Ukraine and issued...