The Ukraine State Fiscal Service recently issued a guidance letter concerning the VAT liability on certain services provided by a Ukraine resident to a non-resident. The letter notes that in accordance with Article 186.4 of the Ukraine Tax Code, the place of supply of services is the place where the service provider is registered, unless otherwise specified in Article 186. Such specified services include those under Article 186.3, which are considered to be supplied where the recipient of services is registered as a business entity or, in the absence of such a place, the place of permanent or primary residence. These services include consulting, engineering, legal, accounting, audit, and actuarial services, as well as services for the development, supply, and testing of software, among others. Where such services are provided by a resident to a non-resident, the place of supply is considered outside Ukraine and, therefore, not subject to VAT.
Source Orbitax
