of November 8, 2012 No. 2426/0/141-12/D/17-1114
Concerning the taxation of income gained by resident in the form of insurance premiums
The State Tax Service of Ukraine, according to Art. 52 of the Tax code of Ukraine of 02.12.2012 No. 2755-VI (further - the Code), considered within the competence the letter concerning the taxation of income gained by resident in the form of insurance premiums and reports.
By subitem 14.1.54 "e" of Item 14.1 of article 14 of the Code it is determined that the income with source of their origin from Ukraine is the any income gained by residents or nonresidents including from any types 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 is not exclusive, the income in type of awards on insurance.
By subitem 14.1.47 of Item 14.1 of article 14 of the Code it is determined that the additional benefits are means, material or non-material values, services, other income types which are paid it (are provided) to the taxpayer by the tax agent if such income is not the salary and it is not connected with accomplishment of obligations of labor hiring or is not remuneration under the civil agreements (agreements) signed with such taxpayer (except the cases which are directly provided by regulations of the Section IV of this Code).
According to item 163.1 of Art. 163 of the Section of the Code the taxation object of the taxpayer (both the resident, and the nonresident) is, in particular, the total monthly (annual) taxable income which consists of the amount of the taxable incomes added (paid, provided) within such reporting tax month.
In case of determination of taxation basis all income of the taxpayer gained by it as in cash, and non-cash forms (item 164.3 of Art. 164 of the Code) is considered.
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