CRS is expanding: Ukraine will receive more information about foreign accounts

International tax transparency is moving to the next level.

Ukraine already participates in the automatic exchange of financial-account information under the CRS standard.

Now, the CRS framework itself is expanding significantly.

The updated standard extends coverage to new digital financial products, including certain electronic-money products and central bank digital currencies.

The changes also concern indirect investments in crypto-assets through derivatives and investment structures.

For business owners, however, the key point is different: the information exchanged between tax authorities is becoming more detailed.

In particular, the updated CRS strengthens identification and reporting rules for companies’ controlling persons.

What does this mean in practice?

If a Ukrainian tax resident has:

• an account with a foreign bank;
• a foreign company;
• an interest in a foreign structure;
• an investment account;
• certain digital financial assets;
• the status of a controlling person of a foreign company,

information about that structure may enter the international automatic-exchange system.

This creates the main tax risk.

The State Tax Service may compare information received from abroad with the taxpayer’s Ukrainian tax return, CFC reporting, and other taxpayer data.

For example:

CRS shows a foreign account →
the bank identifies the individual as a Ukrainian tax resident →
a foreign company also exists →
but no CFC information or corresponding income is reported in Ukraine.

Such inconsistencies may potentially trigger questions from the tax authorities.

CRS should not be confused with CARF.

CRS primarily covers financial accounts and specified financial products.

CARF is a separate international standard for the automatic exchange of information on crypto-asset transactions.

Ukraine is also preparing for this area: in 2026, the OECD Global Forum held specialised training for representatives of the State Tax Service on the practical implementation of CARF.

A much broader system is therefore gradually taking shape:

• CRS → foreign financial accounts;
• CFC rules → foreign companies and control over them;
• CARF → crypto-asset transactions.

These systems should no longer be viewed separately.

For the owner of an international business, the key question today is not: “Will the State Tax Service see my foreign account?”

The key question is: “Does the information that the State Tax Service may receive from abroad match what I declare in Ukraine?”

This should be reviewed before the tax authority conducts its own comparison.

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

Do you have foreign accounts, companies, or assets? We will review your structure for CRS, CFC, and international tax-information exchange risks.

📞 096 574 81 02
📧 info@uk-winner.com

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