Can a single tax payer invest money in the authorized capital of another legal entity?

Ukrainian law provides that a legal entity that pays a single tax of the third group has the right to contribute funds or property to the authorized capital of another legal entity. In this case, such person may be the founder of another legal entity with a share of up to 25%, 100% in the authorized capital. 

Thus, according to Art. 291 of the Tax Code one can not be a single tax payer of entities whose authorized capital is a set of shares owned by other legal entities that are not payers of a single tax is equal to or exceeds 25%. That is, the share of founders in the amount of not less than 75% of the authorized capital of a legal entity that plans to choose a simplified taxation system should belong to legal entities - payers of a single tax.

This is stated in the individual tax consultation of 17.01.2020, № 160 / ITC / 05-99-04-04.

However, it should be borne in mind that the acquisition and sale by a legal entity - a single tax payer of the third group of corporate rights of other legal entities on a permanent basis can be considered as financial intermediation.

A pp. 6 pp. 291.5.1 Art. 291 of the Tax code stipulates that the sole tax cannot be paid by the third group of legal entities operating in the field of financial intermediation.

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