Joint investment is a relevant tool for attracting capital, allowing to combine the resources of individuals and legal entities in order to generate profit and develop the economy. The study is aimed at analyzing the tax aspects of the functioning of joint investment institutions (CIIs) in Ukraine and their impact on the investment climate. The theoretical basis of the study is the provisions of the Tax Code of Ukraine, in particular the preferential tax regime for CII income.

The results showed that preferential taxation of income from CII activities stimulates the attraction of investors, reduces the tax burden and increases the efficiency of capital mobilization. The benefits include exemption from income tax on income received from CII assets and allow reinvesting profits without additional taxation, which creates favorable conditions for the development of the stock market.

The practical significance lies in improving models of tax incentives for investment activities, which will contribute to stable economic growth, the creation of new jobs and the development of infrastructure. Thus, co-investment is an effective mechanism for raising funds and stimulating economic development.

Collective investment is a mechanism that allows different investors to pool their resources to invest in projects or assets in order to make a profit. One of the most common instruments of collective investment is investment funds, which combine the funds of individuals and legal entities to achieve common investment goals. In this context, issues arise related to the taxation of such funds and the investment participants themselves.

The collective investment mechanism, enshrined in the Law of Ukraine "On Collective Investment Institutions", allows not only to effectively service investment projects, but also to significantly optimize the company's cash flows. Regardless of the type and type, the main task of collective investment institutions is to mobilize funds, which will subsequently be invested in various securities and other assets and will contribute to the development and improvement of the financial market of Ukraine. In this sense, an important aspect of the activities of CII is their preferential taxation, since it affects the final amount of income received by the investor.

The activities of investment funds are designed to promote more effective use of financial savings of individuals and legal entities by involving them in the investment process in the state. Thanks to collective investment institutions, individual investors are united, as a result of which an advantage is achieved in the investment process. The experience of industrially developed countries shows that collective investment institutions can significantly influence the stock market, and through it the development of the state economy as a whole.

The basis for building models of more effective tax planning remains the benefit from corporate income tax. The conditions of taxation in the field of collective investment are determined by the Tax Code of Ukraine.

In accordance with paragraph 141.6 of Article 141 of the Tax Code of Ukraine, any collective investment vehicles are exempt from income tax. In particular, funds contributed by founders and participants of a corporate investment fund (CIF) to the authorized capital and assets of the fund; income from transactions carried out with CIF assets; various types of income from CIF activities: interest on loans that a CIF or a mutual investment fund (PIF) may provide to companies-shareholders of the fund; rent that a CIF may receive if its asset is leased; royalties that may be transferred to the CIF if intellectual property rights are registered for the fund, etc. Therefore, any income accumulated in a CIF is exempt from taxes while this money remains in the fund.

Taxation occurs only when the investor:

• alienates CIF securities to a third party (in the event of a profit from sale);
• presents the securities of the CII for redemption to the issuer (corporate investment fund or mutual investment fund asset management company);
• receives investment income as a result of the payment of dividends by the collective investment institution, if the payment of dividends is provided for by the registration documents of the CII (closed-type investment funds).

From January 1, 2017, in accordance with subparagraph 167.5.4 of Article 167 of the Tax Code of Ukraine, income of individuals in the form of dividends from collective investment institutions (CIIs) is taxed at a rate of 9% personal income tax and 1.5% military levy. This creates a total tax burden on this income of 10.5%. For comparison, other income of individuals is taxed at a rate of 18% personal income tax plus 1.5% military levy. At the same time, for dividends on shares, investment certificates, corporate rights accrued by non-residents, collective investment institutions or entities that are not payers of income tax, half the rate established in paragraph 167.1 of this article is applied.

Tax instruments are an important factor in stimulating investment activity in Ukraine. They are aimed at creating a favorable environment for business development, attracting capital and increasing the competitiveness of the economy.

Let us consider the key mechanisms operating in this area.

1. Development and implementation of a comprehensive system for applying tax incentives for investment activity in accordance with the approved strategic priorities of the country's socio-economic development. Such an approach will allow overcoming its current selectivity. After all, the Tax Code of Ukraine "preserves the sectoral and point type of granting tax benefits." Moreover, there are reasons to believe that in the last few years, the action of such instruments in Ukraine is not aimed at forming an operational and effective mechanism for their application, improving the investment climate and creating a real positive image on the world stage. Instead, the goal is only a nominal increase in the country's position in international ratings, as evidenced by the statements and program documents of the government.
2. Expanding the range of existing tax instruments. The timely introduction of such instruments as benefits for reinvested profits, investment tax credit, tax deductions. In addition, when forming the conditions for their use, the interests of small and medium-sized businesses - the main driver of the modern market economy, especially in the territorial dimension of its development - should be a priority.
3. Implementation of the American model of tax incentives for investment activities, respectively, granting local governments more powers to develop and implement a strategy for using tax instruments for investment purposes. The resulting tax competition between territories will not only increase the investment attractiveness of each of them separately and the country as a whole. To a certain extent, it will simplify the role of the state in this process, leaving the central authorities mainly with controlling and regulating functions. This will allow for a more efficient and transparent implementation of a policy of stimulating investment activities.
4. Introduction of tax benefits for individual investors. Today, tax incentives are designed only for the process and results of entrepreneurial activity, as well as for stimulating individual mortgage lending, which we do not consider sufficient.
5. Creating an algorithm for using tax instruments to stimulate investment activity, which would provide solutions not only to economic, but also to certain social problems. In particular, it is advisable to reform tax benefits in the direction of promoting not only the growth of GDP, but also the stable emergence of new jobs, improving the quality of infrastructure, solving problems of development of territorial communities, etc.

Thus, joint investment is an important mechanism for combining the resources of different investors in order to make a profit. Thanks to joint investment institutions, capital is mobilized and financial flows are optimized, which has a positive effect on the development of the economy and the stock market of Ukraine. Preferential taxation of income related to the activities of CII creates additional incentives for attracting investors and increasing the profitability of investments. Thus, joint investment not only contributes to a more efficient use of funds, but also improves the investment climate in the country.