of September 5, 2012 No. 948/0/141-12/L/17-1114
About the taxation of the income of nonresidents
According to subitem 14.1.213 of item 14.1 of Art. 14 of the Code for the purpose of the taxation the nonresident the physical person which is not resident is considered.
The income with source of its origin from Ukraine - any income gained by residents or nonresidents including from any kinds of their activities in the territory of Ukraine (including payment (charge) of remuneration by foreign employers), its continental shelf, in exclusive (sea) economic zone, including, but it is not exclusive, the income in type of inheritance, gifts, prizes, prizes according to subitem 14.1.54 "е" item 14.1 of Art. 14 of the Code.
The nonresident who gains income with source of their origin from the territory of Ukraine and has the diplomatic privileges and immunity established on the terms of reciprocity by the international treaty which consent to be bound is this the Verkhovna Rada of Ukraine, concerning income gained by it directly from implementation to such diplomatic or equated to it by such international treaty other activities is not taxpayer.
According to Art. 162 of the Code taxpayer on the income of physical persons is, in particular, the physical person - the nonresident which gains income from source of their origin in Ukraine.
The taxation of income gained by nonresidents is determined in item 170.10 of Art. 170 of the Code.
Income with source of their origin in Ukraine which is charged (is paid, provided) for benefit of nonresidents, is assessed with tax by the rules and rates determined for residents (taking into account the features determined by some regulations of this Section for nonresidents (subitem 170.10.1 of item 170.10 of Art. 170 of the Code)).
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