The Ukraine State Fiscal Service has published guidance letter No. 6986/6/99-99-15-02-02-15 concerning the country's interest deduction restriction for related-party debt. The letter clarifies that where a Ukraine taxpayer's average debt-to-equity ratio exceeds 3.5:1 (10:1 for financial institutions and companies engaged exclusively in leasing) for a period, the amount of its pre-tax profits for the period must then be increased by the amount of non-resident related-party interest expense fo…