CRS becomes more detailed: from 2027, the tax authority will receive more data

International automatic exchange of tax information is moving to a new level. On 4 September, the State Tax Service of Ukraine announced the introduction of the new CRS XML Schema v3.0 starting in 2027.

This is not merely a technical update. The new schema will introduce additional reporting fields, enabling a more detailed exchange of information on foreign accounts, companies, and legal structures.

What is changing:

• The scope of financial instruments is expanding to include electronic money products and central bank digital currencies.
• CRS will cover indirect investments in crypto-assets, including those made through derivatives and investment structures.
• A separate framework, CARF, is being developed for direct crypto-asset transactions.

Ukraine is already working on amendments to its national reporting procedures.

What does this mean for Ukrainian tax residents?

The receipt by the State Tax Service of information about a foreign account does not automatically constitute a violation. However, this information may be used to compare it with data declared by the taxpayer.

Questions may arise regarding:

• tax residency;
• foreign income and controlled foreign companies (CFCs);
• sources of funds;
• consistency between declared income and taxes paid.

The key question is shifting from “Will the State Tax Service see this?” to “Does what the State Tax Service sees match what I declare in Ukraine?”

It is better to seek legal advice now than to require legal representation later.

Consultations on CRS, CFCs, and digital assets:
📞 096 574 81 02
📧 info@uk-winner.com

Author: Ihor Yasko, Managing Partner at WINNER Law Firm, PhD in Law.