Since the provision of crew (personnel) of the vessel is not an independent service, but is an integral part of the time charter (rental of the vessel), the place of supply of such service is determined in accordance with the place of supply of vehicle rental services, including sea, river), namely the place of supply is the place of registration of the provider of such services, so regardless of whether they are provided to a resident or non-resident, such services are subject to taxation on a general basis at the basic rate.
Source: visnuk.com.ua
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