The Ukraine State Fiscal Service (SFS) recently published guidance letter No. 6345/6/99-99-15-02-02-15 concerning withholding tax on income derived by a non-resident as part of a joint venture (activity) agreement involving business activities in Ukraine. According to the letter, persons engaged in joint activities without a legal entity shall be considered a separate entity in such activities for tax purposes. In such case, the accounting of the results of the joint activity can be assigned…