LETTER OF THE STATE TAX SERVICE OF UKRAINE

of February 9, 2012 No. 1706/5/15-3416

The State Tax Service of Ukraine considered the letter '...' concerning charge of the value added tax on the postage due also reports.

According to subitem 196.1.5 of Item 196.1 of article 196 of the Tax Code of Ukraine of December 2, 2010 No. 2755-VI (further - the Code) are not the transaction taxation object on provision of services on collection, settlement cash servicing, attraction, placement and return of means under agreements of the loan, the deposit, contribution (including pension), to management of means and securities (corporate laws and derivatives), the order, provision, management and departure of rights to claim on financial loans of financial institutions, credit guarantees and the bank guarantee of person who granted such loans, guarantees or guarantees.

The list of standard transactions on settlement cash servicing which according to subitem 196.1.5 of Item 196.1 of article 196 of the Code are not the taxation object, No. 400 approved by the resolution of Board of the National Bank of Ukraine of 15.11.2011.

Settlement and cash servicing according to the Law of Ukraine "About payment systems and money transfer in Ukraine" are services which are provided by bank to the client based on the relevant agreement signed between them which are connected with money transfer from the account (into the account) this client, issue of means to it in cash form, and also implementation of other transactions provided by agreements.

Thus, services in settlement cash servicing which are provided to UDPPZ of Ukrpocht and from which the postage due is paid are assessed with the value added tax in accordance with general practice.

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