LETTER OF THE STATE TAX SERVICE OF UKRAINE

of February 28, 2012 No. 3534/6/12-0016

Concerning confirmation of the right to application of provisions of the international treaty

The State Tax Service of Ukraine considered the letter of TD Dnepr Plast LLC of 29.01.2012 No. 29 concerning legitimacy of use at the beginning of 2012 of the reference for 2011 on confirmation of the status of the tax resident of the country with which the international treaty on avoidance of double taxation is signed, and reports the following.

According to provisions of item 103.4 of article 103 of the Tax Code of Ukraine (further - the Code) the basis for release (reduction) from the taxation of the income with source of their origin from Ukraine is representation by the nonresident taking into account the features provided by Items 103.5 and 103.6 of this Article, to person (tax agent) who pays it the income of the reference (or its notarially certified copy) which confirms that the nonresident is resident of the country with which the international treaty of Ukraine is signed (further - the reference), and also other documents if it is provided by the international treaty of Ukraine.

According to provisions of item 103.8 of article 103 of the Code person who pays the income to the nonresident in reporting (tax) year in case of submission of the reference by the nonresident with information for the previous accounting tax period (year) can apply provisions of the international treaty of Ukraine, in particular concerning release (reduction) from the taxation, in reporting (tax) year with receipt of the reference after the termination of accounting (tax) year.

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