LETTER OF THE MAIN STATE TAX AUTHORITIES OF UKRAINE

of July 23, 1997 No. 12-0117/10-5833

About application of agreements about avoidance of double taxation

In the last time in mass media in connection with commissioning of the Law of Ukraine "About introduction of amendments to the Law of Ukraine "About the taxation of profit of the companies" does not absolutely correctly treat provisions of Item 18.3 of article 18 of the Law and the letter of State Tax Administration of Ukraine of 06.02.97 N 12-0117/10-901 "About rates of tax on separate income types". With respect thereto the State Tax Administration explains it.

By Item 18.3 of article 18 of the Law of Ukraine "About introduction of amendments to the Law of Ukraine "About the taxation of profit of the companies" it is determined that it is necessary to understand the nonresidents created in the countries with which Ukraine has no the international treaties on avoidance of double taxation ratified by the Verkhovna Rada of Ukraine as the nonresidents created in offshore zones. As of 01.07.97 (for information of the Ministry of Foreign Affairs of Ukraine) the international agreements of Ukraine about avoidance of double taxation with 16 countries, namely with Belarus, Big Britain, Armenia, Denmark, Estonia, Kazakhstan, Canada, Latvia, Moldova, the Netherlands, Norway, Poland, Slovakia, Hungary, Germany, Sweden took effect.

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