LETTER OF THE STATE TAX SERVICE OF UKRAINE

of February 4, 2013 No. 1673/6/15-3115

About consideration of the address

The State Tax Service of Ukraine considered the letter of rather some tax matters the value added tax of advertizing transactions and reports.

According to Item 2 of article 17 of the Economic code of Ukraine the laws which regulate the taxation of subjects of managing shall provide elimination of double taxation.

According to Item 185.1 of article 185 of the Tax Code of Ukraine (the Code is farther) the taxation object the value added tax are transactions of taxpayers, in particular, on:

to delivery of goods which place of delivery is located on customs area of Ukraine;

to delivery of services which place of delivery is located on customs area of Ukraine.

According to Item 198.3 of article 198 of the Code the tax credit of the accounting period is determined proceeding from the contractual (contractual) cost of goods/services, but it is not higher than the level of regular prices, and consists of the amounts of the taxes accrued (paid) by the taxpayer at the rate, stipulated in Item 193.1 articles 193 of this Code during such accounting period in connection with:

acquisition or production of goods (including in case of their import) and services for the purpose of their further use in taxable transactions within economic activity of the taxpayer;

acquisition (construction, construction) of fixed assets (fixed assets, including other non-current tangible assets and incomplete capital investments into non-current capital assets), including in case of their import, for the purpose of further use in taxable transactions within economic activity of the taxpayer.

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