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законопроєкт №0382 про ратифікацію Конвенції між Україною та Австралією щодо усунення подвійного оподаткування доходів та запобігання податковим ухиленням і уникненню
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Ukraine and Australia are preparing new taxation rules

Потрібна допомога адвоката? Залишай заявку On 20 August, Draft Law No. 0382 was registered with the Verkhovna Rada of Ukraine. The draft law concerns the ratification of the Convention between Ukraine and Australia for the elimination of double taxation of income and the prevention of tax evasion and avoidance. The official register of Verkhovna Rada draft laws confirms that the document was registered specifically on 20 August. For most Ukrainian companies, Australia may seem like a distant market. However, for business owners, investors, and companies that already make—or plan to make—payments between Ukraine and Australia, this is an important tax development. An international tax convention determines which state, and under what conditions, has the right to tax a particular type of income. This concerns, in particular, cross-border business activities, investment income, and other payments between residents of the two states. One point is especially important to understand. A double taxation avoidance convention does not provide an automatic exemption from taxes. To benefit from its provisions, it is necessary to correctly determine tax residency, the transaction structure, the status of the income recipient, and to meet all conditions stipulated by applicable law. Therefore, once ratification is completed, Ukrainian businesses working with Australia should review their existing agreements and payment structures. This is particularly important where substantial amounts are involved. In international tax planning, it is important not only to comply with the law. It is also important not to pay more tax than a business is legally required to pay under domestic law and the applicable international treaty. Verkhovna Rada of Ukraine — Draft Law No. 0382 WINNER Law Firm advises on international business structuring, controlled transactions, foreign economic activity, investment agreements, and international taxation matters. Would you like a consultation? Call: 096 574 81 02. Email: info@uk-winner.com You can seek legal advice now so that you do not have to seek defence counsel later. Author: Ihor Yasko, Managing Partner of WINNER Law Firm, Candidate of Legal Sciences (PhD in Law). https://www.youtube.com/watch?v=UvayosIccBo

законопроєкт №15518 зареєстрований 17 серпня 2026 року удосконалює правила трансфертного ціноутворення
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Transfer Pricing: Rules for Working with the State Tax Service May Change

Потрібна допомога адвоката? Залишай заявку Ukraine is preparing changes to the rules governing transfer pricing and the resolution of international tax disputes. The changes concern Draft Law No. 15518, which addresses advance pricing agreement procedures for controlled transactions and mutual agreement procedures. For most entrepreneurs, transfer pricing may seem like a rather narrow tax issue. However, for large businesses, international groups, and companies conducting controlled transactions with non-residents, a transfer-pricing error may result in millions of hryvnias in additional tax assessments. This is especially relevant to transactions between related companies, exports and imports, royalties, financing, or transactions with non-residents from certain jurisdictions. The main problem does not arise when the State Tax Service has already initiated an audit. It arises much earlier—when the transaction structure and pricing approach were designed incorrectly from the outset, or when the business cannot properly substantiate them. That is why the advance pricing agreement mechanism is particularly relevant for large businesses. The logic is straightforward: in cases defined by law, rather than waiting for the State Tax Service to challenge a transfer price several years later, a company can agree in advance on the methodology for determining whether the terms of controlled transactions comply with the arm’s length principle. This is especially important for large international groups, where a single tax dispute may arise simultaneously in several jurisdictions. Therefore, companies involved in controlled transactions should view transfer pricing not merely as an annual report to be filed with the State Tax Service. Transfer pricing is part of an international business structure that should be designed before a transaction is carried out—not explained after an audit has begun. The WINNER Law Firm provides legal support for international business structuring, controlled transactions, foreign economic activity, investment agreements, and international taxation matters. Would you like a consultation? Call: 096 574 81 02. Write to: info@uk-winner.com You can seek legal assistance now so that you do not need to seek legal defense later. Author: Ihor Yasko, Managing Partner at WINNER Law Firm, PhD in Law. https://www.youtube.com/watch?v=UvayosIccBo

Постановою КМУ від 10.06.2026 № 765 перехідний період продовжено до 31 грудня 2027 року.
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New EU-standard requirements are being prepared for agricultural machinery

Потрібна допомога адвоката? Залишай заявку Ukraine continues to align technical requirements for agricultural machinery with European Union legislation. The Ministry of Economy has published a draft of new functional safety requirements for agricultural and forestry vehicles. For manufacturers and importers of agricultural machinery, this is not merely another change in technical regulation. The proposed requirements may directly affect whether a particular machine can complete conformity-assessment procedures and be lawfully placed on the Ukrainian market. Ukraine already has a Technical Regulation on the type approval of agricultural and forestry vehicles, approved by Cabinet of Ministers Resolution No. 28. It is designed to align Ukrainian regulation with the European model. For businesses, this means that not only formal documentation requirements are gradually changing. The focus is on machinery specifications, testing, conformity assessment, and the documentation required for placing machinery on the market. This creates the principal risk for importers. Machinery may already have been purchased abroad, the contract signed, an advance payment made, and logistics arranged — only for it to become clear at the import or market-placement stage that the specific model or its documents do not meet the new requirements. Manufacturers face a different risk: they may need to adapt their products and conformity-assessment procedures. Therefore, manufacturers, dealers, and importers of agricultural machinery should monitor the progress of the draft and verify technical documentation, certification, and the terms of foreign trade contracts in advance. This is especially important before purchasing large batches of machinery. It is far less costly to verify the requirements before signing a contract and paying for the goods than to solve a problem after the machinery has already arrived in Ukraine. Current Technical Regulation — Verkhovna Rada of Ukraine. WINNER Law Firm supports imports and foreign economic transactions, helping businesses with certification, technical regulation, customs clearance, and disputes with regulatory authorities. Would you like a consultation?📞 Call: +38 096 574 81 02📧 Email: info@uk-winner.com You can seek legal services now so that you do not have to seek litigation services later. Author: Ihor Yasko, Managing Partner of WINNER Law Firm, PhD in Law. https://www.youtube.com/watch?v=UvayosIccBo

ДПС переходить до системного аналізу податкових ризиків: що це означає для бізнесу
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The State Tax Service is moving to a systematic analysis of tax risks: what this means for businesses

Потрібна допомога адвоката? Залишай заявку On 19 August, the State Tax Service of Ukraine once again drew businesses’ attention to the implementation of a tax risk management system, known as compliance risk management. This is part of the National Revenue Strategy through 2030. It is important to understand that the tax authority’s approach itself is changing. The State Tax Service is gradually moving away from a model in which the supervisory authority reacts only to a specific violation, towards a model where a taxpayer’s risks are analysed systematically. The tax authority identifies four main categories of risks:— risk of taxpayer registration;— risk of late filing or failure to file reports;— risk of incorrect or incomplete tax reporting;— risk of late tax payment. This is an important signal for businesses. What matters now is not only whether a company has committed a specific violation. A company’s overall tax behaviour also matters: how it reports, what it declares, how it pays taxes, whether its actual activities correspond to its registration data, and where the system identifies potential risks. At the same time, Resolution No. 854 does not establish any new obligations or restrictions for taxpayers. Officially, the State Tax Service promotes a preventive approach: consultations, explanations, and an opportunity for taxpayers to adjust their conduct come first, while audits are intended as a last resort. However, the practical conclusion for businesses is different: it is important to understand how your company appears through the eyes of the State Tax Service’s system before an audit arises. This is especially relevant for companies with substantial input VAT credits, complex transaction structures, numerous counterparties, non-standard financial flows, or significant fluctuations in their tax burden. Therefore, a tax audit today is no longer merely a search for mistakes already made. It is an opportunity to identify in advance the risks that the State Tax Service may identify tomorrow. Primary source: State Tax Service of Ukraine, 19 August 2026. WINNER Law Firm conducts tax audits for businesses, assesses high-risk transactions and business models, supports tax audits, challenges tax assessment notices, and protects companies’ interests in disputes with the State Tax Service. Would you like a consultation?📞 Call: +38 096 574 81 02📧 Email: info@uk-winner.com You can seek legal services now so that you do not have to seek litigation services later. Author: Ihor Yasko, Managing Partner of WINNER Law Firm, PhD in Law. https://www.youtube.com/watch?v=UvayosIccBo

Стаття 209 КК України легалізація майна одержаного злочинним шляхом
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The Mudra case: why article 209 of Ukraine’s criminal code is among the most difficult to prove

Потрібна допомога адвоката? Залишай заявку There are many sensational headlines surrounding the case of Iryna Mudra today. However, as a lawyer, I would not rush to draw conclusions based solely on the publicly disclosed investigation materials. Article 209 of Ukraine’s Criminal Code — the legalisation of property obtained through criminal means — is one of the most complex categories of criminal proceedings, particularly in terms of proving the case. For the prosecution, it is not enough to demonstrate the movement of funds, their deposit through banking institutions, the use of intermediaries, or even a complex system of financial transactions. The key issue is the criminal origin of the property and proof that a specific person knew, or should have known, about that origin. In practice, the prosecution must build a coherent chain of evidence: establish the origin of the funds, the circumstances in which they were obtained, their subsequent movement, the role of a particular person, and that person’s subjective attitude towards the relevant transactions. This is where the most difficult part begins. A financial transaction in itself is not money laundering. The movement of funds is not money laundering either. Acquaintance or communication between the individuals involved also does not, by itself, prove intent to launder money. Published audio recordings and other materials may create a strong impression in the public sphere. However, criminal proceedings operate under different rules. The court must assess the lawfulness of obtaining and the admissibility of each piece of evidence, the context of conversations, the body of evidence as a whole, the actual role of each person involved and, especially important for Article 209 of Ukraine’s Criminal Code, whether the required subjective element of the criminal offence has been proven. Therefore, there can be a significant legal distance between a high-profile suspicion under Article 209 of Ukraine’s Criminal Code and a conviction. It is the court — not media headlines or publicly disclosed fragments of investigation materials — that must make the final determination of guilt. Until then, the presumption of innocence applies. In criminal proceedings, a properly chosen defence strategy from the first days often determines the subsequent outcome of the case. You can seek legal advice now rather than needing legal representation later. Author: Ihor Yasko, Managing Partner at the WINNER Law Firm, PhD in Law. https://www.youtube.com/watch?v=UvayosIccBo

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The BES is already identifying risks before criminal proceedings are initiated

Потрібна допомога адвоката? Залишай заявку On 18 August, the Bureau of Economic Security of Ukraine (BES) released the performance results of its Territorial Department in the Poltava region for the first half of 2026. For businesses, the key point is not so much the statistics of criminal proceedings, but rather how the BES is now identifying potential violations. Over six months, BES analysts prepared 47 analytical reports concerning risks of possible criminal offences in the budgetary, tax, and monetary and credit sectors. The total value of transactions in which the BES identified such risks exceeded UAH 2 billion. This is an important signal. Some of these analytical materials have already served as grounds for initiating criminal proceedings. In other words, a business may now come to the attention of the BES even before a search, questioning, or notice of suspicion. Separately, BES analysts identified risks exceeding UAH 483 million in public procurement and issued 10 recommendations to state authorities. Overall, during the first half of the year, detectives of this territorial department conducted pre-trial investigations in 292 criminal proceedings, issued notices of suspicion to 53 individuals, and referred 34 cases to court. For businesses, this means a change in approach. The BES does not necessarily wait until a violation has been established within criminal proceedings. Its analysts examine transactions, tax information, procurement activities, and financial links in an effort to identify risks in advance. That is why it makes sense to conduct a business criminal-law audit before law-enforcement authorities take an interest in the company. This is particularly relevant for businesses with substantial turnover, complex tax structures, public procurement activities, budget funds, and significant transactions with counterparties. The purpose of such an audit is straightforward: to assess the business through the eyes of a BES analyst before the BES itself does so. Primary source: Bureau of Economic Security of Ukraine, 18 August 2026. WINNER Law Firm conducts criminal-law and tax audits for businesses, assesses risks related to economic crimes, and provides legal defence for companies and officers in criminal proceedings. Would you like a consultation?📞 Call: +38 096 574 81 02📧 Email: info@uk-winner.com You can seek legal services now so that you do not have to seek criminal defence services later. Author: Ihor Yasko, Managing Partner of WINNER Law Firm, PhD in Law. https://www.youtube.com/watch?v=UvayosIccBo

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Obtaining funds under the guise of cryptocurrency investments: a lawyer’s perspective

Потрібна допомога адвоката? Залишай заявку Cryptocurrency investments have become one of the most common tools used by fraudsters in Ukraine. Over the past year alone, law-enforcement authorities have exposed dozens of criminal organisations that allegedly obtained funds from citizens ranging from millions to tens of millions of hryvnias. This article examines the legal aspects of such offences, common fraud schemes and defence strategies. Why it matters: major cases in 2025–2026 Examples include: October 2025, Odesa: a transnational network involving fictitious investments allegedly transferred investors’ funds to crypto wallets and spent them. The suspects face up to 12 years’ imprisonment. November 2025: pseudo-trading platforms allegedly misappropriated funds from EU citizens; more than USD 1.4 million in cash was seized. July 2026: a criminal organisation allegedly defrauded nearly one thousand Ukrainians of more than USD 1.1 million under the guise of cryptocurrency-investment training. August 2026: law-enforcement authorities shut down 94 fraudulent call centres, including those operating under the guise of crypto investments. Common fraud schemes Fake investment platforms Fraudsters create professional-looking websites that imitate legitimate trading platforms. After transferring funds, the victim sees a supposed “profit” on the screen. However, when attempting to withdraw funds, they are required to pay alleged “taxes” or “fees.” The platform later disappears. High-pressure call centres Call-centre operators contact potential victims while posing as managers of investment companies. Using pre-prepared scripts, they persuade people that there is a “unique opportunity” and help them “open an account quickly.” Funds are then transferred to crypto wallets controlled by the fraudsters. Financial pyramids disguised as crypto projects Organisers create “innovative” projects promising passive income. Early participants receive payments funded by new investors, but when the inflow of money slows, the pyramid collapses. Legal status of cryptocurrency In Ukraine, cryptocurrency is recognised as a virtual asset and an object of civil rights. This means that crypto assets can be the subject of an offence, and their value for calculating damages is determined in hryvnia equivalent at the time the offence was committed. Defence strategies Distinguishing participants’ roles It is critically important to establish the specific role played by each suspect. Organisers face more severe liability than ordinary participants. Reviewing the legality of searches Searches and the seizure of devices must be conducted in accordance with procedural requirements. Violations may provide grounds for evidence to be ruled inadmissible. Challenging the amount of damage Alleged losses are often overstated or unsupported by evidence. The defence may request an independent expert assessment and recalculation. Preventive measures In cases involving especially serious offences, courts often order pre-trial detention. The defence may propose alternatives, such as bail or house arrest. Advice for investors: red flags Guaranteed high returns without risk, such as 20% or more per month. No licences or registration with financial authorities. Pressure to act urgently: “the offer is valid today only.” Requests to transfer funds to private crypto wallets rather than official accounts. Inability to withdraw funds without making additional payments. Aggressive calls from alleged “managers.” Conclusion Obtaining funds under the guise of cryptocurrency investments remains one of the most serious categories of criminal offences in Ukraine. The sanctions under Articles 190, 255 and 209 of the Criminal Code of Ukraine provide for up to 12 years’ imprisonment with confiscation of property. As a lawyer, I urge anyone who has come under suspicion to seek professional legal assistance without delay. A properly chosen defence strategy at the early stages may materially affect the outcome of the case. Nazar Al-MziraviAttorney at Law, specialising in criminal law and defence in fraud and organised-crime cases, WINNER Law Firm. If you or someone close to you is in a similar situation, please seek a consultation. https://www.youtube.com/watch?v=N9Rdi6CWE1s

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Exposure of a criminal organisation in the Dnipropetrovsk region: a lawyer’s commentary

Потрібна допомога адвоката? Залишай заявку Law enforcement authorities in the Dnipropetrovsk region recently reported exposing a criminal organisation that allegedly used a fraudulent call centre to obtain almost UAH 1.7 million from Israeli citizens. This case illustrates how telephone fraud has evolved into complex organised criminal activity with a clear hierarchy and specialised roles. Case facts According to the investigation, members of the alleged criminal organisation set up a fraudulent call centre in Kamianske. From there, they called potential victims while posing as employees of banks, mobile operators or internet service providers. Using pre-prepared call scripts, the suspects allegedly obtained access to victims’ online banking accounts and misappropriated their funds. Key details: At least five foreign nationals were identified as victims. On 11 August 2026, police conducted a series of searches at the suspects’ homes, in vehicles and at the call centre’s office premises. The following were seized: more than UAH 1.6 million, approximately USD 76,000, more than EUR 30,000, bank cards, mobile phones, computer equipment, four vehicles, documents and records. Nine individuals were notified of suspicion. The whereabouts of one further suspect are being established. Criminal-law classification The suspects are alleged to have committed criminal offences under the following provisions. Article 255 of the Criminal Code of Ukraine: criminal organisation Article 255 of the Criminal Code of Ukraine establishes liability for establishing or leading a criminal community or criminal organisation, as well as for participation in one. Part 1 of Article 255 — establishing or leading a criminal organisation: Penalty: imprisonment for a term of 5 to 12 years, with confiscation of property. Part 2 of Article 255 — participation in a criminal organisation: Penalty: imprisonment for a term of 3 to 8 years. Importantly, an offence under Article 255 is considered complete from the moment the organisation is formed or a person joins it, irrespective of whether its members have committed specific offences. Article 190 of the Criminal Code of Ukraine: fraud In this case, the suspects are alleged to have committed an offence under Part 5 of Article 190 of the Criminal Code of Ukraine: fraud committed on an especially large scale or by an organised group. Part 5 of Article 190 Penalty: imprisonment for a term of 5 to 12 years, with confiscation of property. For fraud, an “especially large scale” is defined as an amount exceeding 600 tax-free minimum incomes of citizens. At present, this exceeds UAH 10,200. The alleged loss in this case—UAH 1.7 million—significantly exceeds that threshold. Part 4 of Article 28 of the Criminal Code of Ukraine: commission of an offence by an organised group The additional classification under Part 4 of Article 28 emphasises that the alleged offence was committed by an organised group—that is, a group of persons who previously formed a stable association to commit this and other offences. Why the case matters This case demonstrates several troubling trends in contemporary crime: Transnational nature. The victims are Israeli citizens, indicating the cross-border scale of the organisation’s alleged activity. High level of organisation. Each participant allegedly performed a separate function, while all actions formed a single scheme to obtain funds. Professional approach. The use of pre-prepared call scripts and impersonation of bank and telecom employees. Significant amounts. The seizure of UAH 1.6 million, USD 76,000 and EUR 30,000 points to the alleged systematic and large-scale nature of the activity. Practical defence considerations As a criminal defence lawyer, I identify several key areas of work in organised-fraud cases. Distinguishing participants’ roles In cases involving criminal organisations, it is essential to establish the specific role each suspect played. Organisers and leaders face significantly more severe liability than ordinary participants. Reviewing the lawfulness of searches and seizures The series of searches conducted on 11 August must be carefully reviewed for compliance with procedural requirements. Any violations may provide grounds for evidence to be ruled inadmissible. Proving the amount of damage The investigation is determining the “full amount of damage” and identifying “all victims.” The defence may challenge the alleged amounts where they are not supported by proper evidence. Preventive measures: detention The issue of imposing pre-trial detention on the suspects is currently being considered. In cases involving especially serious offences—such as Part 5 of Article 190 and Part 1 of Article 255 of the Criminal Code of Ukraine—courts often select detention, particularly where: there is a risk of absconding from the investigation; evidence may be destroyed; suspects may continue criminal activity. Advice for citizens This case is a reminder to remain vigilant: Never disclose bank-card details, online-banking passwords or CVV codes over the phone. Do not trust calls from alleged “bank employees,” “police officers” or “technical support” demanding urgent action. Verify the information: if someone claims to call from your bank, independently call the bank’s official hotline. Do not install remote-access software, such as TeamViewer or AnyDesk, at the instruction of unknown persons. Stay calm: fraudsters often create artificial panic, for example by claiming that “your account has been hacked” or that “a security deposit is urgently required.” Conclusion The exposure of the alleged criminal organisation in the Dnipropetrovsk region is an important signal for both law enforcement and the public. For the suspects, the case will be a serious challenge, as it concerns especially serious offences carrying the most severe sanctions. For society, it is a reminder that telephone fraud remains a current threat requiring ongoing vigilance. As a lawyer, I encourage anyone suspected in similar cases to seek professional legal assistance immediately. A properly selected defence strategy at the early stages of criminal proceedings can materially affect the outcome of a case. Nazar Al-MziraviAttorney at Law, specialising in criminal law and defence in fraud and organised-crime cases, WINNER Law Firm. If you or someone close to you is in a similar situation, please seek a consultation. https://www.youtube.com/watch?v=N9Rdi6CWE1s

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New rules are being prepared for crypto businesses: licensing, stablecoins and currency controls

Потрібна допомога адвоката? Залишай заявку Ukraine’s cryptocurrency market is gradually approaching a point where operating without clear rules will become much more difficult. On 17 August, the National Securities and Stock Market Commission of Ukraine (NSSMC) announced preparations for the future regulation of the virtual-assets market and identified four issues that must be resolved before the framework can be fully launched. This directly affects crypto exchanges, exchange services, fintech companies and other businesses working with virtual assets. First — licensing. The regulator is discussing which types of activities will require a licence and how demanding the licensing requirements should be. This is a fundamental issue: excessively strict requirements could drive part of the business to other jurisdictions. Second — stablecoins. Their legal status and rules for circulation need to be defined. This is particularly important for businesses that use stablecoins for settlements, liquidity management or cross-border transactions. Third — currency controls. One of the key issues is how to reconcile transactions involving virtual assets with the current currency restrictions and requirements of Ukraine’s financial system. Fourth — international crypto platforms. Ukraine needs to determine under which rules global market participants will be able to serve Ukrainian users, and whether a separate local presence or authorisation in Ukraine will be required. The NSSMC expressly notes that the virtual-assets market already exists in Ukraine—it is simply operating outside a fully developed regulatory framework for now. Therefore, the question is no longer whether regulation will be introduced, but what form it will take. For crypto businesses, this means that now is the time to review their corporate structure, company jurisdictions, AML/KYC procedures, customer-service models, flow of funds and the tax implications of transactions involving virtual assets. Once regulation comes into force, restructuring a business model may be significantly more expensive than preparing it in advance. Original source: NSSMC, 17 August 2026 WINNER Law Firm advises on the structuring of crypto and fintech businesses, taxation of virtual assets, financial monitoring, international structures and regulatory risks. Would you like a consultation?📞 Call: +38 096 574 81 02📧 Email: info@uk-winner.com You can seek legal advice now so that you do not later need legal defence. Author: Nazar Al-Mziravi, Attorney at Law, WINNER Law Firm. https://www.youtube.com/watch?v=UvayosIccBo&t=8s

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Up to UAH 200 million for the restoration of industrial parks: what businesses need to know

Потрібна допомога адвоката? Залишай заявку The state has strengthened support for industrial parks whose infrastructure has been damaged or destroyed as a result of hostilities. And the amounts involved are already quite substantial. To restore damaged engineering and transport infrastructure in an industrial park, the state may finance up to 80% of the project’s estimated cost, but no more than UAH 200 million per park. Applications for restoration are considered on a priority basis. However, there is an important condition: the application must be submitted no later than six months after the damage to the facility occurred. For frontline areas, the preferential 80/20 co-financing mechanism has also been expanded. This means that the state may cover up to 80% of the costs of creating or modernising engineering and transport infrastructure or connecting to the power grid. However, UAH 200 million is not simply money that the state transfers for reconstruction. Receiving funding is conditional upon meeting the established requirements, and the project itself requires proper legal and documentary preparation. In particular, the general programme requires the commissioning of at least 5,000 sq. m of industrial buildings and the involvement of at least two processing enterprises. For owners and management companies of industrial parks, this means that before submitting documents, they should verify land and infrastructure rights, properly document the damage, prepare a cost estimate and restoration project, and assess whether they can meet the state incentive requirements. This is particularly relevant for industrial sites in frontline regions. Therefore, in such projects, the legal framework should be developed before state funds are received—not when questions arise about how those funds are used or whether the assumed obligations have been fulfilled. 🔗 Original source: Ministry of Economy of Ukraine — terms of state incentives for industrial parks in 2026 WINNER Law Firm advises on investment and industrial projects, financing structuring, land and corporate matters, and helps businesses assess legal, tax, and criminal-law risks. Would you like a consultation?📞 Call: +38 096 574 81 02📧 Email: info@uk-winner.com You can seek legal advice now so that you do not later need legal defence. Author: Ihor Yasko, Managing Partner at WINNER Law Firm, PhD in Law. https://www.youtube.com/watch?v=UvayosIccBo&t=8s

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