Ukraine:
Withholding Tax On Foreign To Foreign Sales
03 September 2021
Andersen in the UK
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Harking back to the Vodafone India case, the State Tax Service
of Ukraine has recently clarified that a non-resident purchaser
must withhold tax on capital gains derived by a non-resident seller
in the case of a sale of shares in a Ukrainian company.
Gains arising on the sale by the non-resident shareholder to the
non-resident purchaser will be liable to WHT at 15% unless reduced
pursuant to a relevant double tax treaty. In such circumstances,
the purchaser must first register with the Ukrainian tax
authorities before making any payment for the Ukrainian company
shares. The tax withheld by the purchaser must be paid over to the
State.
Originally published June 2021
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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