LETTER OF THE STATE TAX SERVICE OF UKRAINE

of February 6, 2012 No. 2282/6/15-1415

About consultation provision

The State Tax Service of Ukraine considered the letter concerning reference of the special invoice (the deed of conveyance of the provided services) to the list of other documents which confirms the fact of provision of consulting company services to the nonresident the Ukrainian company and reports.

According to paragraph 2 of item 137.1 of Art. 137 of the Tax code of Ukraine (is farther - the Code) the income from provision of services and performance of works is recognized by date of creation of the act or other document processed according to requirements of the current legislation which confirms performance of works or provision of services.

According to item 135.2 of Art. 135 of the Code the income is determined based on source documents which confirm receipt of the income by the taxpayer, obligation of maintaining and which storages it is provided by rules of conducting financial accounting, and other documents established by the Section II of this Code.

In particular, by item 44.1 of the Art. of 44 rubles of the II Code it is determined that for the purposes of the taxation taxpayers shall record the income, expenses and other indicators connected with determination of the taxation objects and/or tax liabilities based on source documents, bookkeeping registers, the financial reporting, other documents connected with calculation and tax payment and charges which conducting is stipulated by the legislation.

Forming of indicators of tax statements based on the data which are not supported by the documents determined by the first paragraph of this Item is forbidden to taxpayers.

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