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LETTER OF THE STATE TAX SERVICE OF UKRAINE

of March 28, 2012 No. 5508/6/15-2216f

To the All-Ukrainian accounting BALANS-AGRO edition

The State Tax Service of Ukraine considered your letter of 28.02.2012 No. 04-39/35750 concerning the right to application of the fixed agricultural tax as a result of reorganization of agricultural enterprise which arrived from Committee of the Verkhovna Rada of Ukraine concerning finance, banking activity, tax and customs policy by the letter of 29.02.2012 No. 04-39/10-237, and reports the following.

The fixed agricultural tax (further - FSN) is carried to special tax regime which determines special procedure for its collection and other its components and elements and is regulated by the Section XIV "Special tax regimes" of the Tax code of Ukraine (further - the Code).

According to Item 301.1 of article 301 of the Code payers of the fixed agricultural tax taking into account restrictions, stipulated in Item 301.6 these Articles, can be agricultural producers at whom the share of agricultural commodity production for the previous tax (reporting) year equals or exceeds 75 percent.

By the same Article it is determined that if the agricultural producer is formed by merge, accession, transformation, separation or allocation according to the relevant standards of the Civil code of Ukraine, then the regulation concerning observance of share of agricultural commodity production which equals or exceeds 75 percent for the previous tax (reporting) year, extends on: all persons separately who merge or join; each individual formed by separation or allocation; the face formed by transformation.

At the same time, according to Item 301.2 of article 301 of the Code the agricultural producers formed by merge or accession can be taxpayers in year of education if the share of agricultural commodity production received for the previous tax (reporting) year by all producers who participate in their education equals or exceeds 75 percent.

Considering the given, agricultural enterprise formed by merge or accession according to the relevant standards of the Civil code of Ukraine can be the payer of FSN in year of education in case of observance of share of agricultural commodity production by each agricultural enterprise which merges or joins.

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