The Ukraine State Fiscal Service recently published guidance letter No. 1825/ITC/17-00-12-01-06 of 25 April 2019 on the VAT treatment of software development and testing services provided by Ukraine residents to non-residents. The letter notes that as per Section 186.3 of Article 186 of the Tax Code, the place of supply of such services is considered the place of residence of the recipient. Since software services provided to a non-resident would be considered supplied outside Ukraine, such …