Tax officials in an individual tax consultation explained: since a resident pays tax at his own expense at a rate of 20% of the amount of payments to non-residents for the production and / or distribution of advertising, regardless of where the non-resident provided such services, the rules of international treaties in terms of reducing (exempting) the amount of tax do not apply to payments to non-residents.
Fiscal authorities reminded that the application of the rules of international treaties of Ukraine is carried out by the exemption from taxation of income with the source of their origin from Ukraine, by reducing the tax rate or by returning the difference between the amount of tax paid and the amount to be paid by non-resident according to the international treaty of Ukraine.
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