Ukraine's State Fiscal Service (SFS) recently published guidance letter No. 11654/6/99-99-15-02-02-15, which clarifies the tax treatment of discounts provided by a Ukraine resident to a non-resident. According to the letter, discount income is within the scope of taxable income from Ukrainian sources. As such, if discount income is actually paid to a non-resident, such as in the form of a refund, the income is then subject to withholding tax at the standard 15% rate. However, if the discount …