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LETTER OF STATE TAX ADMINISTRATION OF UKRAINE

of January 16, 1998 No. 20/13/16-1110

About the value added tax

The fund of support of the Russian culture in Ukraine is All-Ukrainian public charity foundation. The purpose of activities of Fund is accumulation of funds for their further direction for financing of programs of support of development of the Russian culture in Ukraine.

The law of Ukraine of 16.09.97 N 531/97-BP "About charity and charitable organizations" determines the general principles of charity. The main directions and the purpose of charity are directed to improvement of financial position of receivers of the charitable help, assistance of social resettlement of needy, jobless disabled people, other persons which need guardianship, and also assistance to persons who because of the physical or other defects are limited in realization of the rights and legitimate interests; assistance to citizens who suffered owing to natural disaster, environmental, technological, technogenic and other disasters as a result of the social conflicts, accidents, and also to the victims of repressions, refugees.

The fund organizes collection of charitable gifts and fees from physical persons and legal entities of Ukraine, foreign states and the international organizations both in the form of money, and in the form of property.

At the expense of the specified means the Fund carries out cultural and educational work (organizes exhibitions, festivals, recitals, concerts, exhibitions, lectures, creates the cultural and educational organizations and on-stage performance groups); organizes scientific conferences, seminars and other scientific and educational actions, that is carries out financial and economic activities.

According to Item 3.1.1 of article 3 of the specified Law the taxation object are transactions of taxpayers on sales of goods (works, services) on customs area of Ukraine, including transaction on payment of cost of services in agreements of operational lease (leasing) and transaction on transfer of property on subjects to pledge to the borrower (creditor) for repayment of accounts payable of the pledger, and also on free provision of goods (works, services).

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