Complex legal advice on taxation of income paid to a non-resident in Ukraine for freight forwarding of imported goods is provided. Recommendations on income tax optimization were developed with a transition from a rate of 15% to exemption from taxation pursuant to the Convention between Government of Ukraine and Government of the Republic of Hungary on Avoidance of Double Taxation with respect to taxes on income and estate.

The terms of cooperation with the non-resident-forwarder were analyzed and the legislation of Ukraine and the Civil Code of Hungary were applied to change the contractual terms and conditions to minimize tax expenses.

The case was important for building a legal position between the client and the tax inspection, as The State Tax Service of Ukraine expresses an opinion on non-resident income taxation at the rate of 15%.