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VAT on Corporate Rights Sales: Tax Authorities Explain Input Tax Allocation under Article 199

  • The sale of corporate rights for cash (e.g., a share in an LLC) is not subject to VAT under Article 196.1.1 of the Ukrainian Tax Code, so no VAT liability or tax invoice arises.
  • Even though the transaction is not a VAT object, its value must still be reported in line 5 of the VAT return and in Appendix 5.
  • The tax authority says such a sale counts as a non-taxable operation for purposes of Article 199, so it affects the partial VAT credit allocation rules.
  • The value of sold corporate rights must be included in the total supply volume when calculating the share of taxable vs. non-taxable use of goods/services and fixed assets under Article 199.2.

Source: news.dtkt.ua

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.



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