Subparagraph 23 of Article 264 of the Tax Code has been amended to clarify that this limitation applies only to those persons who are registered in states with preferential taxation.
That is, the full paragraph is set out in the following wording:

Deductible are not subject to:
23) expenses for the acquisition from a non-resident – related party registered in a state with preferential taxation, of management, consulting, advisory, consulting, auditing, design, legal, accounting, advocacy, advertising, marketing, franchising, financial (except for remuneration expenses), engineering, agency services, royalties, rights to use intellectual property objects.

A similar amendment adopted to subparagraph 3-2 of paragraph 1 of Article 288 of the Tax Code also became effective as of January 1, 2023, as follows:

Article 288. Reduction of taxable income
1. The taxpayer shall be entitled to reduce taxable income by the following types of expenses:
3-2) expenses for the acquisition of management, consulting, advisory, consulting, auditing, design, legal, accounting, advocacy, advertising, marketing, franchising, financial (except for remuneration expenses), engineering, agency services, royalties, rights to use intellectual property objects from a non-resident – related party registered in a state with preferential taxation – in the amount of the total amount not exceeding 3 percent of taxable income.

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