Ukraine's State Fiscal Service has published guidance letter 564/6/99-00-07-02-02-15/IPK of 3 October 2019 concerning the treatment of a cross-border sale of corporate rights (shares) as controlled. The letter notes that a certain transaction may be considered controlled if it affects the taxable income of a taxpayer, including business transactions with non-resident related parties and certain other cases. Further, the taxpayer's annual income must exceed UAH 150 million and its transactions…