Having considered all nuances of reflection in accounting of such transactions in the article “Importing without import: Accounting” it should be focused on the peculiarities of their taxation.
Company income tax
According to para.134.1.1 of the Tax Code of Ukraine (hereinafter – TCU), the subject to company income tax is a profit with a source of origin from Ukraine and outside its territory, which is determined by adjusting (increasing or decreasing) of financial result before tax (profit or loss), defined in the financial statements of the company in accordance with national accounting (standards) regulations (hereinafter - accounting regulations) or International Financial Reporting Standards (hereinafter - IFRS) for tax differences arising under the provisions of para.III of TCU. If the income of the company does not exceed UAH 20 million for the financial year, it is possible not to adjust the financial result in accordance with accounting regulations or IFRS.
There are not provided for some specific adjustments in determining of the subject of company income tax in para.III of TCU in terms of the receipt of goods from a non-resident outside the customs territory of Ukraine (except cases of application of norms of Art. 39 of TCU).
VAT
According to paragraph 185.1 of TCU, the subjects to the value added tax (hereinafter - VAT) are transactions of the tax payers on importation of goods into the customs territory of Ukraine.
The placing of goods under the customs regime of “Importing”, defined by the Customs Code of Ukraine, is considered equivalent to such transactions for the purposes of VAT taxation.
When importing goods without import into the customs territory of Ukraine, their placement in customs regime “Importing” does not occur. In other words, this transaction is not the subject to VAT.
