LETTER OF THE DISTRICT STATE TAX SERVICE OF UKRAINE

of May 25, 2012 No. 11284/10/06-038

(Endurance)

The district State Tax Service - the Central office on servicing of large taxpayers of GNS considered the letter... and within the powers reports the following. Concerning question No. 2

According to item 198.1 of Art. 198 p. The V Tax code of Ukraine of December 2, 2010 No. 2755-VI, with changes and amendments (further NKU), the right to reference of tax amounts to the tax credit arises in case of implementation of transactions on:

a) to acquisition or production of goods (including in case of their import to customs area of Ukraine) and services;

b) to acquisition (construction, construction, creation) of non-current assets, including in case of their import to customs area of Ukraine (including in connection with acquisition and/or import of such assets as and/or by transfer of such assets on balance of the taxpayer, representative to record fee in authorized capital results of joint activities);

c) to receipt of the services provided by the nonresident on customs area of Ukraine and in case of receipt of services which place of delivery is the customs area of Ukraine;

d) to import of non-current assets to customs area of Ukraine under agreements of operational or financial leasing.

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