Is the loan repaid by the guarantor included in the tax base of the PE?

In accordance with Clause 177.2 of Art. 177 of Chapter IV of the Civil Code, the object of taxation is the net taxable income, i.e. the difference between the total taxable income (revenue in monetary and non-monetary form) and documented expenses related to the economic activity of such a natural person – an entrepreneur.

At the same time, the income received by an individual entrepreneur both in cash and in kind is included in the total taxable income, namely:

  • revenue in the form of non-cash funds received in a bank account or in cash directly to the entrepreneur or his employees at the place of settlement (including bank interest);
  • revenue in kind (non-monetary form);
  • amounts of fines and penalties received from other business entities under civil law contracts for violation of the terms of contracts and other incomes related to the implementation of business activities.

According to Art. 1054 of the Civil Code of Ukraine under a credit agreement, a bank or other financial institution (lender) undertakes to provide funds (loan) to the borrower in the amount and on the terms established by the agreement, and the borrower undertakes to return the loan and pay interest.

Taking into account the fact that a loan received by an individual entrepreneur from a bank to a current account is subject to repayment, this amount of the loan is not subject to inclusion in income.

At the same time, if the loan is repaid by a legal entity – the guarantor, then the income, in the amount of the loan repaid by the guarantor, is included in the income (earnings in cash and in kind) and is subject to personal income tax according to the rules established by Art. 177 PKU.