Ukraine Tax Intelligence – Digital Platform Reporting, APA Framework, Progressive PIT & State Budget 2027

Executive Summary

Ukraine implements DAC7-aligned digital platform reporting, introduces an APA framework, proposes progressive PIT and CFC rules, and sets 2027 unified tax limits with a higher minimum wage. Regional collections show strong growth amid enforcement upgrades.

Important Updates

Digital Platform Taxation & DAC7 Implementation

Ukraine has enacted a comprehensive regime for taxing income derived from digital platforms, aligning with OECD MRDP and EU DAC7. Law No. 4123-IX (published 23 Oct 2026, effective 1 Jan 2027) introduces Chapter 12.1 to the Tax Code, imposing annual reporting obligations on platform operators (resident and non-resident) for transactions in property rental, personal services, goods sales, and transport rental. Operators must collect and verify seller TINs, report gross income, fees, and taxes withheld by 31 January annually. Non-resident operators without a PE must appoint a Ukrainian tax representative. A 5% withholding tax applies to gross payments to non-resident sellers; resident individuals face 18% PIT + 1.5% military levy on net income after a 20% standard deduction. The STS Order No. 1124 details reporting mechanics, and methodological guidelines (Letter No. 19-2026) specify tax base calculations. Ukraine also acceded to the MCAA for automatic exchange of digital platform seller data with 112 jurisdictions starting 2027. Penalties for non-compliance include UAH 51,000 per platform per period and potential platform blocking.

Platforms must register in the STS Digital Platform Register by 1 Dec 2026 and implement real-time tax calculation engines by 1 Jul 2027. The deemed supplier rule makes platforms liable for VAT on sales by non-VAT-registered sellers to Ukrainian consumers. Technical specifications for XML reporting (OECD DPI v1.0) were published 15 Nov 2026.

Advance Pricing Agreements (APA) Framework

The STS released comprehensive guidance on Advance Pricing Agreements under Tax Code Articles 39.1–39.5 (Law No. 2123-IX, 2024) and STS Order No. 888 (2025). APAs are available for cross-border controlled transactions exceeding UAH 50M annually, with three types: unilateral, bilateral (with treaty partner), and multilateral. Terms run 3–5 years with possible rollback up to two prior years. Application fee is UAH 200,000 (non-refundable). Evaluation takes 12 months (24 for bilateral). Taxpayers must submit a functional analysis, comparability study, and proposed transfer pricing method (CUP, TNMM, profit split). The framework aligns with OECD TP Guidelines and BEPS Action 13. First bilateral APA signed with Poland (2026); negotiations ongoing with Germany, Netherlands, Switzerland. Applications accepted year-round via the e-cabinet APA Module; master file, local file, and CbC report required for MNE groups with revenue > EUR 750M.

Sources: STS APA Guidance

Planned Tax Changes: Progressive PIT, CIT Interest Limitation, CFC Regime

The Ministry of Finance published a “Tax Modernization Roadmap 2027-2028 ‘o’utlining three pillars: (1) linking pension tenure to tax incentives – individuals with 35+ years insurance tenure receive an additional UAH 2,000 monthly non-taxable minimum; (2) progressive PIT rates – income above UAH 100,000/month taxed at 20%, above UAH 200,000/month at 25% (currently flat 18%); (3) CIT base broadening via interest deductibility limitation – net interest expense deductible up to 30% of tax EBITDA (aligned with EU ATAD 2), with 5-year carryforward of disallowed interest. A new controlled foreign company (CFC) regime will attribute undistributed income of low-taxed foreign subsidiaries to Ukrainian resident shareholders. Public consultations run until 31 Dec 2026; draft laws expected Q1 2027. Progressive PIT estimated to generate UAH 45B annually. Taxpayers should model payroll impacts by Mar 2027; CFC reporting (Form КФК-1) due with 2027 CIT return (by 31 Mar 2028).

Sources: Ministry of Finance Roadmap

State Budget 2027: Unified Tax Limits, Minimum Wage & Subsistence Minimum

The Verkhovna Rada adopted the State Budget 2027 (Law No. 3456-IX) setting new unified tax turnover limits effective 1 Jan 2027: Group 1 (no employees) raised from UAH 1M to UAH 1.2M; Group 2 (up to 10 employees) from UAH 5M to UAH 6M; Group 3 (any employees) from UAH 7M to UAH 8.5M. A new Group 4 for agricultural producers introduced with UAH 20M limit. Unified tax rates unchanged: Group 1 – 10% of subsistence minimum (UAH 320/month); Group 2 – 20% of minimum wage (UAH 1,600/month); Group 3 – 3% of revenue (VAT registered) or 5% (non-VAT). Minimum wage increased to UAH 8,000 (from UAH 7,100) and subsistence minimum to UAH 3,200 (able-bodied) from 1 Jan 2027, impacting Group 1/2 fixed taxes, salary floors, sick leave, maternity pay, and USC accrual thresholds. Employers must update payroll systems by 15 Dec 2026; FOPs on Groups 1/2 will receive revised payment notices in Dec 2026.

Sources: Budget 2027 Unified Tax Limits | Minimum Wage & Subsistence Minimum

Secondary Regulatory & Regional Updates

Employer-Paid Medical Insurance: STS confirms employer-paid voluntary health insurance premiums up to UAH 34,650/year per employee are exempt from PIT and military levy if the policy meets statutory criteria (licensed insurer, medical-only coverage). Excess amounts taxed at 18% PIT + 1.5% military levy. Employer may deduct premiums for CIT capped at two minimum wages/employee/year. SSC (22%) still applies on premium. Reporting via Form 1DF by 1 Feb 2027. STS Clarification | VHI Details
Land Tax Exemption for Destroyed Property Extended to 2027: Cabinet Resolution No. 1087 extends land tax/rent exemption for plots with destroyed buildings through 31 Dec 2027 (previously 2026). Exemption automatic based on State Register of Damaged Property; no application needed for land tax. Lessees must notify lessor within 30 days of destruction confirmation. Partial destruction (>50%) qualifies for prorated exemption. Reconstruction terminates exemption. Taxpayers must ensure registration in SRDP by 31 Mar 2027. STS Extension | Cabinet Resolution | Application Procedure
Certificate of Tax Residence: STS guide for obtaining TRC (Form 1-DF) via Electronic Cabinet or paper. Issued within 10 business days, valid 12 months, no fee. Required for claiming benefits under 85+ DTTs. STS Guide
Fuel Expense Reimbursement Rules: Reimbursement up to 200 liters/month per employee (actual documented receipts) exempt from PIT, military levy, and USC. Excess taxable. Employer CIT deduction allowed within limit. No VAT deduction on fuel for personal vehicles. STS Clarification
Anti-Fraud Restrictions on Excise Stamp Sales: STS Letter No. 2841/2026 caps monthly stamp sales at 120% of average monthly production; distributors must report daily to AESAS. Direct sales between taxpayers prohibited. Violations trigger license suspension and fines UAH 170K-340K. Integration with AESAS API required by 1 Nov 2026. STS Position
New Transport Tax Declaration Form Effective 2027: STS Order No. 912 introduces consolidated electronic Form 1-TT from 1 Jan 2027, replacing separate vehicle declarations. Filing deadline 20 Feb following year; payment 31 Mar. Vehicle data in State Register must be accurate by 1 Dec 2026. STS Order
Currency Control Requirements Under Martial Law: STS/NBU guide: export proceeds repatriation within 90 days; 30% mandatory currency sale (down from 50%); import advance payments capped at UAH 2M equivalent without NBU license; crypto treated as barter, FEA registration required over UAH 400K. Joint Guide
Real Estate Tax Benefits for Single Parents: Tax base reduction of 120 sq m (apartment) or 250 sq m (house) for single parents with child under 18 (or 23 if student). Applied automatically if data matches; otherwise submit docs by 1 Mar. STS Clarification
Regional Tax Collection Updates: Prykarpattia (Ivano-Frankivsk): UAH 4.8M transport tax from luxury vehicles (192 taxpayers, 100% collection); UAH 40.2M tourist tax Jan-Sep 2026 (+12% YoY). Transport Tax | Tourist Tax
Regional Tax Collection Updates: Dnipropetrovsk: UAH 42.2B to state budget Jan-Sep (+9.3% YoY), driven by CIT (+14.2%) and VAT (+11.8%). 1,240 documentary audits, 380 field audits, UAH 1.1B additional assessments. Regional Report
Regional Tax Collection Updates: Kherson: UAH 6.9B consolidated budget Jan-Oct (+8% YoY); UAH 5.7B for social expenditures (+6.2% YoY). Improved compliance via SAF-T UA and automated payroll cross-checks. Consolidated Budget | Social Expenditures
Regional Tax Collection Updates: Kharkiv: UAH 74B taxes/fees Jan-Oct (+12.4% YoY). SAF-T UA mandatory for large taxpayers, Pulse risk system flagged 1,200 high-risk declarations. Military levy contributed UAH 4.8B. Regional Report
Regional Tax Collection Updates: Kirovohrad: UAH 2.4B military levy Jan-Oct (+9.1% YoY); total UAH 21.3B all budgets (+10.7% YoY). VAT 38%, CIT 22%, PIT 18%, USC 15%. SAF-T UA reduced VAT gap 12%. Military Levy | Total Collections
Regional Tax Collection Updates: Odesa: Top 5 industries: trade 32%, transport/port 24%, manufacturing 18%, real estate/services 14%, construction 8%. VAT payments +13.4% YoY (UAH 1.2B increase) due to SAF-T UA enforcement and e-Invoice pilot. Industry Breakdown | VAT Growth
Regional Tax Collection Updates: Zaporizhzhia: UAH 12B Jan-Sep (+11.3% YoY). VAT 35%, CIT 25%, PIT 16%, USC 14%, single tax 12%. Military levy UAH 800M. Pulse flagged 600 high-risk declarations. Regional Report
Regional Tax Collection Updates: Cherkasy: UAH 1.1B VAT refunds Jan-Sep (+14.2% YoY). Auto-refund pilot for clean-history taxpayers (10 days). Export growth 9%. VAT Refunds
Procedure for Documenting Property Loss Due to Hostilities: STS Letter No. 18-2026: Form 1-Loss within 30 days (extendable to 90), confirmation from military admin/SES, adjust VAT purchase book and CIT expense register, VAT credit reversal for destroyed inputs. No penalty interest during martial law. STS Letter
STS Analytical Dashboard for Single Tax Group 3: Public dashboard “Single Tax Group 3 ‘i’n Pulse service shows active payers, collections, turnover, compliance, migration, audit results. Updated monthly, open data, API available. Dashboard Launch
Updated Excise Stamp Rules for Tobacco Industry: Mandatory electronic pre-ordering via e-cabinet from 15 Nov 2026; revised excise calculation for heated tobacco (specific + ad valorem); real-time EGAIS reporting of stamp affixing within 24h. Penalties: 50% unpaid excise for missing pre-order, UAH 17K for late EGAIS report. Updated Rules
Draft Law on Land Plots Under Apartment Buildings: Draft No. 12345-1 simplifies privatization of land under multi-apartment buildings, sets fixed land tax 0.5% (down from 1%), shifts payment responsibility to condominium association (OSMD) as tax agent. Proposed effective 1 Jan 2027. Draft Law
Launch of Unified Factoring Register: NBU/STS register operational test mode until 31 Dec 2026, mandatory from 1 Jan 2027. All factoring agreements must be registered within 3 business days. Auto-verifies VAT invoices via URTI. Late registration fine UAH 5K per agreement. Factoring Register
Draft Budget Code Amendments on Escrow Accounts: Draft No. 12346 defines “cash security expenditures”, new budget code KEKV 2119, mandates escrow registration in ProZorro and Treasury STA module. Release requires STS tax compliance verification. Effective 1 Jan 2027. Draft Amendments
Draft Law on Real Estate Brokerage Licensing: Alternative draft No. 12347 introduces mandatory licensing (UAH 5K individual, UAH 20K company), professional liability insurance (UAH 500K), public register, tax agent obligations for PIT/military tax on commissions, monthly Form 1-РБ reporting. Proposed effective 1 Jul 2027. Draft Law
Updated PPP/Concession Reporting Requirements: New Form З-ППП requires CAPEX/OPEX split, revenue sharing, tax payments, KPIs, ESG metrics. Auditor certification, electronic submission via ppp.gov.ua by 31 Mar 2027 for 2026. Penalties: UAH 50K private partner, UAH 20K public partner. Updated Reporting
FOP Group 2 Restrictions for Foreign Client Services: STS Letter No. 3456/11/2026: Group 2 FOPs can serve foreign clients only if service performed entirely in Ukraine (place of supply = Ukraine). Cross-border digital services lose Group 2 eligibility; must switch to Group 3 or general system. Foreign-sourced revenue excluded from UAH 5M turnover limit. Targeted audit campaign Q1 2027. STS Clarification
Weekly STS Digest of Tax Clarifications: STS published weekly digest (6 Nov 2026) summarizing official clarifications, court decisions, electronic reporting updates, VAT refunds, CIT adjustments, PIT deductions, military levy. No new legal norms but critical for aligning with administrative practice. Weekly Digest
Disability Employment Contribution Reporting Deadline: Employers with 25+ employees must submit report by 9 Nov 2026 (Form per STS Order No. 274). Contribution rate 2.5x minimum wage per unfilled 4% quota. Late filing penalty UAH 1,700 (UAH 3,400 repeat). Zero report required if quota met. STS Reminder | Media Center
Foreign Income Declaration Payment Deadlines: STS clarifies payment deadline for PIT/military levy on foreign income is 1 Aug following reporting year (e.g., 2025 income due 1 Aug 2026). Filing deadline 1 May. Installments possible if liability > UAH 10K. Foreign tax credits require documentation. STS Clarification | Media Center
Tax Treatment of QR Code Tips: Tips via QR code to personal account are employee income. If processed through employer RRO, employer withholds PIT (18%), military tax (1.5%), USC (22%). If direct to employee, employee self-reports via Form 1DF by 1 May. Non-declaration is tax evasion. STS Clarification
Tax Treatment of Employer-Provided Coffee: Free coffee/tea/water in workplace for general consumption not taxable. Premium coffee, capsules, gift sets, vouchers for external use are taxable benefits (PIT 18% + military 1.5%). Subsidized canteen price difference also taxable. STS Clarification

Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.