CRS 2.0 and digital assets: tax transparency will expand further from 2027

Ukraine continues to expand its participation in the international automatic exchange of tax information.

The State Tax Service has announced Ukraine’s accession to the updated CRS framework, with the expanded exchange of information expected to begin in 2027.

What does this mean for business owners and asset holders?

CRS is gradually expanding to cover a broader range of financial instruments. The changes include certain electronic-money products, while the updated rules also reflect the development of digital financial instruments.

At the same time, CARF is being developed internationally as a separate standard for the automatic exchange of information on crypto-asset transactions.

In practice, this is creating a new system of tax transparency, under which different reporting channels may contain information about:

• foreign bank and financial accounts;
• foreign companies and CFCs;
• electronic money;
• crypto-asset transactions;
• tax residency and controlling persons.

This does not mean that every foreign account, company, or crypto-asset automatically creates a tax violation.

However, if the information received by the State Tax Service from abroad does not correspond to a person’s Ukrainian tax reporting, this may result in information requests, audits, and a need to explain the source of funds and the ownership structure of assets.

A lawyer’s view: 2027 may become the next significant stage in international tax transparency.

Therefore, holders of foreign accounts, CFCs, and digital assets should not wait for a request from the State Tax Service. They should review in advance:

• tax residency;
• CFC reporting;
• declaration of foreign income;
• sources of funds;
• documentary evidence for digital-asset transactions;
• consistency between Ukrainian reporting and information that may potentially be received through international exchange.

WINNER Law Firm provides legal support on CFCs, CRS, international taxation, and digital assets.

Would you like legal advice regarding an international structure, CFCs, CRS, or digital assets?

📞 Call: 096 574 81 02
📧 Email: info@uk-winner.com

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