Ukraine's State Fiscal Service (SFS) recently published guidance letter No. 14510/6/99-99-15-02-02-15, which clarifies the treatment of transactions as controlled when through an agent. According to the letter, when a Ukrainian resident sells goods to a non-resident buyer through a resident agent, the transaction is not considered controlled for the resident seller regardless of the parties being related. However, the transaction may be considered controlled for the resident agent if:
- Its an…