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Tо the State Tax Administration in the Lviv Region
June 27 ,2006
Members of the association "European Union of Ukrainian Transport Companies" provide transport-forwarding services on cargo transportation by railroad means, both on the territory of Ukraine and on outside the customs border of Ukraine. Transportation is performed through a third party – a forwarder. Both residents and non-residents of Ukraine may be the customers of transportation.
Due to amendments to the Law of Ukraine № 168/97-ВР from 03.04.1997 „About the value added tax'', introduced by the Law of Ukraine № 2505-ІУ „About introduction of amendments to the Law of Ukraine „About the State budget of Ukraine for the year of 2005», the Union "EAUTC" is appealing to You with a request to render explanations of certain points of this Law regards the value added taxation of transport-forwarding services provided outside the border of Ukraine:
1. Will the transport-forwarding service (transport tariff) on railroad transportation outside the customs territory of Ukraine (for example, transit through Russia), provided by a non-resident to a resident, be imposed the VAT?
1.1. what will be the object of imposing the tax?
1.2. at what rate /0% or 20%/?
2. Will the transport-forwarding service on railroad transportation outside the customs territory of Ukraine (for example, transportation from Ukraine and Poland) consisting of a forwarder’s service and transportation tariff, provided by a resident to a resident, be imposed the VAT?
2.1. what will be the object of imposing the tax?
2.2. at what rate /0% or 20%/?