of December 20, 1996 No. 22-0113/11-1598
About the taxation of profit of nonresidents
We report that according to the Law of Ukraine "About the taxation of profit of the companies" of 28.12.94 N 334/94-BP nonresidents are income tax payers only in case of implementation of business activity through the permanent missions located in the territory of Ukraine and when implementing repatriation of the profit got from sources in the territory of Ukraine.
At the same time passive profits of nonresidents which do not perform business activity in Ukraine through permanent mission, the income from provision of technical services (type inzhenering) which source is in Ukraine, in case of their repatriation for borders of Ukraine are assessed with tax at the rate of 15 percent if another is not established by the international treaty of Ukraine on tax questions.
According to noted Law profits on corporate laws (dividends), transactions with securities and financial resources, in particular, are enlisted in structure passive (percent).
Vice-chairman Mr. Operenko
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