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.