Operations for export outside the customs territory of Ukraine in the customs regime of export or re-export (if the goods are placed in such a regime in accordance with paragraph 5 of the first part of Article 86 of the ICU) goods that were previously imported into the customs territory of Ukraine in the customs regime of import, their return to a non-resident seller is a VAT-taxable transaction that is taxed at a zero rate, and VAT liabilities in accordance with paragraph 198.5 of Art. 198 TCU in this case are not accrued.
If the export of such goods outside the customs territory of Ukraine is carried out using the regime of exemption from taxation provided for in paragraph 206.5 of Art. 206 TCU, then for such goods the taxpayer must accrue tax liabilities for VAT in accordance with paragraph 198.5 of Art. 198 TCU.
Source: visnuk.com.ua
