LETTER OF STATE TAX ADMINISTRATION OF UKRAINE

of June 8, 2011 No. 10698/6/15-0315

The State Tax Administration of Ukraine considered the letter of joint-stock company concerning application of regulations of the Tax code of Ukraine and reports.

Concerning the cost of groups of fixed assets at depreciation

According to paragraph 5 of the item 6 of subsection 4 of the Section XX "Transitional provisions" of the Tax code of Ukraine (further - the Code) if the total cost of all groups of fixed assets on accounting data is less, than total cost of all groups of fixed assets according to tax accounting for date of the introduction in action of the Section III of this Code, then the temporary tax difference which results from such comparison will be amortized as separate object using rectilinear method within three years.

At the same time, if the total cost of all groups of fixed assets on accounting data is more, then the difference which arises will be amortized in accordance with general practice as a part of the cost of groups of fixed assets.

Concerning inclusion of the amounts of revaluation of fixed assets for depreciation

According to paragraph 1 of the item 6 of subsection 4 of the Section XX "Transitional provisions" of the Code these inventory counts, carried out by condition for April 1, 2011 are applied to determination of the list of fixed asset objects, other non-current and intangible assets on groups according to Item 145.1 of article 145 of this Code for the purpose of depreciation from the date of the introduction in action of the Section III of this Code.

According to paragraph 4 of the item 6 of subsection 4 of the Section XX "Transitional provisions" of the Code the revaluated value of fixed assets does not join the amount of revaluation of fixed assets which is carried out after January 1, 2010.

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