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CII income in the form of royalties

If the terms of the license agreement provide for granting the recipient (buyer) the right to use the object of intellectual property rights (including trademarks) without the possibility of its sale or alienation in another way, the supplier receives payment from the recipient (buyer) as a fee for granting such a right to use the trademark for VAT purposes is defined as royalties and, accordingly, such a transaction is not subject to VAT.

Source: visnuk.com.ua

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