TURKMENISTAN LAW ON VALUE-ADDED TAX

Article 1. General provisions

A value-added tax is a procedure for a part of an added value, being created at all stages to produce goods (works, services) to be assigned to budget.
A value-added tax is to be assigned in the currency of Turkmenistan.

Article 2. Tax payers

1. Entities as follows are considered to be value-added tax payers:

- legal entities, including enterprises with foreign investments, which exercise production and other commercial business;
- branches, affiliates, representative offices of legal entities and other enterprise individual divisions, located at the territory of Turkmenistan, being individually engaged in selling goods (works, services);
- international associations and foreign legal entities, exercising production and other commercial business at the territory of Turkmenistan;
- entities, being engaged in entrepreneur business free of forming a legal entity, provided that proceeds thereof, resulted from selling goods (works, services) is over 10 minimum salaries per year.

2. Enterprises and organizations, specified in paragraph 1, are hereinafter referred to as the enterprise.

Article 3. Taxation objects

The taxation objects are turnovers for goods (works, services), export-import operations inclusive, to be sold at the territory of Turkmenistan.
Items as follows are to be taxed:

- turnovers to sell all goods( works, services) related to own production and purchased aside;
- turnovers to sell goods( works, services) inside enterprise for own consumption, which costs are not to be treated as production and trading costs , as well as for the staff;
- turnovers to sell goods( works, services) free of paying cost by being exchanged for other goods (works, services);
- turnovers to take over goods (works, services) free of charge to other legal or physical entities;
- turnovers to sell pledge items, including transfer thereof to a mortgagee, provided that a pledge obligation has not been fulfilled.

Article 4. Estimation of turnover to be taxed

1. A turnover to be taxed is to be estimated on the basis of goods (works, services) being sold, taking prices and tariffs applied into consideration, not including value-added tax thereto.
A turnover to be taxed for retailers, suppliers and other organizations, while imported goods (works, services) are on sale, is to be estimated, taking their sale price into consideration.
If enterprises obtain financial assistance, funds for charity purposes, various types of borrowing costs (except banking loan), a turnover taxed, related to those amounts, is to be increased for taxation purposes, despite periods they are obtained and to be repaid.
While estimating turnover to be taxed per goods (works, services) being excised, excise amounts are to be included therein.
While fixed assets, goods (works, services) are taken over free of charge or being partially paid, a turnover taxed is to be estimated in the way, specified by Turkmenistan Cabinet of Ministers.
While goods (works, services) are disposed for the enterprise own consumption, costs thereof are not to be treated as production and trading costs, and the cost of those or similar goods (works, services), which has been estimated per prices and tariffs applied, is to serve as a basis estimating turnover to be taxed. The real cost price is to be taken into consideration, if no prices (tariffs) are available.
Provided the goods are made on the basis of the give-and-take stuff and materials, cost to process them is considered to be a turnover taxed.
The back tare cost is not to be included in a turnover taxed, except cases, when tare is sold by the manufacturers.
2. A cost of works done and paid by customers is considered as a turnover to be taxed for building, building-assembly and repair organizations.
3. While enterprises render intermediary services, a turnover to be taxed is a profit earned as extra charges, remuneration and fees.

Article 5. List of goods (works, services) tax exempted

Items as follows are value-added tax exempted:

- services to transport, to dispatch, to offload, to transship foreign cargoes via Turkmenistan territory (transit goods);
- goods and services intended for being officially disposed by the diplomatic and representative offices similar thereto, as well as by the diplomatic and administrative-technical staff personal consumption of those representative offices, including family members, living therewith;
- services of the municipal passenger traffic (except taxi);
- housing and operational services, rendered to population (including rent);
- insurance and reinsurance operations, including services related thereto, being exercised by insurance intermediaries and agents;
- issue and hand over loans;
- operations related to monetary investments, current/settlement and other accounts, payments, transfers, bills and other securities, except brokerage and other intermediary services;
- operations related to the circulation of currency, funds and bank notes, which are considered as legal payment facilities, except disposed for numismatic purposes;
- operations related to the circulation of securities (shares, bonds, certificates, bills, etc.), except operations to produce and store securities, which are to be taxed;
- actions, being exercised by the specially authorized bodies, which are to be officially taxed, as well as services, being rendered by the Bar members;
- payment for entrails;
- services to keep children in infant schools, to take care of sick and old ones;
- funeral and cemetery services;
- payment to teach children and teenagers in hobby groups, sections, studios, for the sport facilities, cultural and education institutions being disposed;
- for the rites and ceremonies to be held by the religious organizations, as well as services of the religious associations;
- goods, being sold by the training-productive enterprises of the blind and deaf;
- turnovers to merchandize values and investments, being confiscated, mismanaged and bought up, as well as values, inherited by the state, except proceeds of trading organizations;
- patent-licence operations (except intermediary ones), related to the industrial property objects, as well as copyrights owned;
- research and development operations, being performed by the budget account;
- turnovers to sell Turkmenistan values to the National depository (NalDep);
- payable medical services for Turkmenistan citizens, medicines being sold within the territory of Turkmenistan, medical items, medical techniques, prosthetic and orthopedic items and special vehicles for invalids;
- own production of students', schools' and of other educational institutes' dinners, and dinners of the hospital/infant and other social-cultural field institutions and organizations, being financed by the budget account;
- services rendered by communication enterprises to deliver pensions and allowances to the population;
- goods (works, services), being manufactured and sold by the therapeutic-production (labor) workshops at the psychiatry and psychoneurologic institutions and invalid public organizations;
- goods (works, services), being produced and sold by enterprises, institutions and organizations, where invalids comprise not less than 50 percentage of the total staff.

The enterprise, institution and organization staff employees are to be included in the average staff list, while identifying right for the remission stated;

- agricultural enterprise own production, being sold against in kind to be paid for labor, as well as to make catering of employees, being attracted to perform agricultural works.

Article 6. Tax rates

20 percentage is to be stated as a value-added tax rate.
While selling goods (works, services) upon prices regulated (tariffs), including a value-added tax therein, 16,67 percentage rate is to be applied.

Article 7. Procedure to estimate tax

  1. Goods (works, services) are to be sold to enterprises upon prices and tariffs, being increased for a value-added tax. Meantime, a tax amount is to be stated by an individual line in the settlement documents for goods (works, services) being merchandized inside Turkmenistan. Goods to be sold, as well as services and works rendered to the population are to be exercised upon prices and tariffs, a value-added tax upon rate stated inclusive.

While production items (works, services) are being sold at the territory of Turkmenistan and abroad, a tax, which has been paid by suppliers for inventory holdings, located at the territory of Turkmenistan, is to be excluded from a total amount to be taxed and assigned to budget. The value-added tax to be assigned to budget is to be stated as a difference between tax amounts, got from the buyers for goods (works, services) merchandized, and tax amounts per tangible resources, fuel, works, services, which value is really to be referred (written off) as production costs in the period under review.
Tax amounts to purchase stuff, materials, fuel, accessories and other items, disposed for basic operational requirements, are not to be referred to the production and trading costs.

2. Taxes as follows are not to be excluded from the total tax amount to be assigned to budget, being paid;

- To suppliers, located outside of Turkmenistan purchasing stuff, materials, fuel, accessories and other items. Those amounts are to be considered in the stuff, materials, works and services value and referred to as production and trading costs;
- for goods (works, services), being used for non-production needs, as well as for fixed assets and intangible assets (cost of proprietary and other rights, "know-how", licences, etc.). Tax for goods (works, services), being used for non-production needs is to be assigned by the account of the relevant financial sources. The fixed and intangible assets are to be accounted per purchase value, including amount of tax paid, with its further writing-off to the cost price via depreciation (amortization) amounts in the established procedure;
- for goods (works, services), being used to perform operations, which are exempted from tax in accordance with the present Law Article 5. The tax amounts, which have been paid by suppliers for such goods (works, services) are to be refereed to the production and trading costs.

Article 8. Procedure and time periods to pay tax

The procedure and time periods to assign a value-added tax are to be stated by the Head National Tax Inspectorate upon agreement with Turkmenistan Ministry of Economy and Finance.
A value-added tax value, being assigned to budget by entities, being engaged in entrepreneur business free of forming a legal entity in accordance with the present Law Article 2, is to be excluded from physical entities profit, being levied on withholding tax.
A value-added tax is to be assigned by enterprises to the relevant budgets upon standards, being yearly stated while budget for the forthcoming year is approved, and by entities, being engaged in the entrepreneur business,
- to the local budgets.

Article 9. Payers responsibility and tax inspectorate supervision

Regulations on Turkmenistan National Tax Inspectorate are to regulate payers' responsibilities for tax legislation being infringed, a procedure for tax inspectorate to exercise supervision and operations for tax officials to be appealed in the court.

Article 10. Final statements

A value-added tax rate, as well as the list of tax remissions, envisaged by the present Law, may be verified while budget for the forthcoming fiscal year is approved.
Instructions for the present Law to be applied is to be worked out and published by Turkmenistan Head National Inspectorate upon agreement with Turkmenistan Ministry of Economy and Finance.

Article 11. The present Law effective date

The present Law is effective since November, 1,1993.

PRESIDENT OF TURKMENISTAN
SAPARMURAT TURKMENBASHY

Ashgabat , 8, October, 1993