LETTER OF STATE TAX ADMINISTRATION OF UKRAINE

of September 20, 1996 No. 22-412/11-5970

About question of the preferential taxation of the companies with foreign investments

Main state tax authorities of Ukraine... concerning the preferential taxation in case of change of the foreign investor reports.

if the qualification foreign investment is not alienated during grace tax period;

if at the company with foreign investments during the grace period the foreign investor without withdrawal from the company of primary qualification foreign investment in the form of property and the related property rights, and also the foreign converted currency changed;

change of the foreign investor took place by transfer by primary foreign investor to other foreign investor of all rights of rather qualification foreign investment with proper legal registration and legalization in consulate of Ukraine then changes and amendments to constituent documents of the company regarding the name of his founders were registered.

Considering stated, the Main state tax authorities of Ukraine consider that as the qualification foreign investment was not alienated during grace tax period and change of productive activity of joint business in connection with change of the foreign investor did not take place, such general company has the right to use profit tax benefit from the moment of its obtaining.

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