Author name: admin

Потрібна допомога адвоката? Залишай заявку At first glance, the shadow coffee market in Ukraine looks like a niche topic, but in fact it exposes problems of fiscal discipline, import control, and competition in the consumer market. When the head of the parliamentary tax committee, Danylo Hetmantsev, publicly talks about “coffee” risks, it is a signal not only for the coffee segment, but for the entire FMCG and HoReCa sectors: the state is shifting from fighting large “schemes” to targeted work with specific product categories. Coffee is convenient for going into the shadow due to its high mark‑ups, stable demand, significant share of imports, and the ability to easily “mask” the product’s origin. On this basis, a layer of businesses is formed — from coffee shops to wholesale importers — that partly or fully operate outside the transparent tax field, and this layer becomes the main focus for risk assessment.The “shadow coffee market” should be understood not only as outright contraband that never passes customs, but also as:– under‑declaration of customs value when importing green coffee or finished blends;– “grey” cash in retail and HoReCa, when actual revenue is far higher than what goes through fiscal tills;– undocumented purchases between wholesalers, roasters, and coffee shops;– product substitution, when one assortment is declared but another is actually sold (more expensive, with a different duty rate, etc.).These practices give unscrupulous players a price advantage: they can afford lower prices or more aggressive rent and marketing policies simply because they do not pay all taxes. For the state this means lost VAT, corporate income tax, and excise (for coffee drinks containing other excisable components); for compliant businesses it means distorted competition and pressure on margins.When Hetmantsev speaks about the risks of the shadow coffee market, the focus is less on the absolute volume of tax evasion and more on the structure of the risks: Fiscal risk. Even relatively small under‑collection in a single niche becomes a problem if the same behaviour is replicated across other product groups. For the budget this is a “multiplier effect”: dozens of categories with modest but systematic levels of shadow activity together create a tangible gap. Risk of distorting the competitive environment. Legal importers, roasters, and coffee‑shop chains are forced either to squeeze their margins or to compromise on product quality just to remain competitive against “grey” players. In the long run this pushes transparent companies out of the market and entrenches the schemes. Reputational risk for the country. Coffee imports are tied to international logistics and financial chains. A large informal component in this business undermines the trust of foreign partners and complicates the development of official supply channels and investments in local roasting, processing, and infrastructure. For the tax committee these risks imply the need for targeted, segment‑by‑segment work: not “cracking down on everyone at once”, but entering each niche with analytics, profiling, and specific risk indicators.If we look at the coffee business chain — from import, customs clearance, and logistics to wholesale and retail/HoReCa — shadow practices can appear at every stage. On import it is the understatement of customs value, the use of offshore intermediaries, “misclassification” in documents, and splitting shipments to avoid the attention of risk‑control systems. Inside the country the most vulnerable area is the cash‑based HoReCa segment: part of sales goes past fiscal tills, and purchases are made through intermediaries without a full set of documents, creating a parallel “invisible” flow of coffee. Another layer of shadowing comes from substituting the quality and composition of ground blends and capsules, when cheaper ingredients are sold as premium product, creating not only fiscal but also consumer protection risks.Public statements about the shadow coffee market signal that the state is moving from generic talk about “de‑shadowing” to focusing on specific niches where risks combine relative simplicity of the scheme with mass‑market volumes. Coffee is exactly such a case: high consumer demand, regular consumption, and a large share of small and medium‑sized businesses.The coffee market also lends itself well to analytics. Authorities can compare official import volumes with internal consumption; the price structure in retail and HoReCa with cost and customs statistics; and the dynamics of registering and closing sole proprietors and companies in the coffee niche with the turnover recorded by fiscal tills. If the numbers diverge significantly, this is a direct trigger for in‑depth audits, sector‑wide campaigns, and adjustments to risk‑based control systems.For transparent businesses the state’s risk assessment has a dual effect. On one hand, tighter control in the niche increases administrative pressure: more information requests, sector audits, test purchases, and price/document monitoring. Companies are forced to invest in compliance, accounting tools, legal support, and staff training. On the other hand, if government measures are systematic and consistent, the compliant segment gets the long‑awaited “clean‑up” of competition: when margins are no longer “stolen” through tax evasion, the playing field levels out, and those who have built better supply chains, service, and product quality remain on the market.Therefore, for legitimate market participants the key is not to resist the very fact of increased scrutiny, but to use the moment to: audit their import, tax, and cash practices; review supply chains for obviously risky intermediaries; and communicate to consumers about transparency, quality, and compliance with international standards.What should businesses do under increased state scrutiny? “Whiten” imports. Correctly declare customs value, work under clear supplier contracts, and remove unnecessary intermediaries and opaque logistics, even if this slightly increases cost. Digitalise retail and HoReCa. Use fiscal tills correctly, integrate them with accounting systems, set internal cash limits, and regularly reconcile stock balances with sales to minimise audit risks. Choose partners carefully. Refuse cooperation with wholesale clients who insist on “simplified” paperwork or cash‑only arrangements, as these are direct sources of fiscal risk and potential involvement in schemes. Build internal compliance. Even in a small chain, introduce basic KYC procedures for key counterparties, standard contracts, and clear document‑flow rules as a minimum but effective shield during active enforcement against the shadow market. If you face questions or

Потрібна допомога адвоката? Залишай заявку Regulatory framework: what is expressly allowed and not prohibitedUkrainian legislation does not contain a direct ban on two or more single‑tax sole proprietors operating in the same premises or at the same retail spot. Each entrepreneur may choose the same address for business activities, register this site with the tax authorities and conclude a separate lease or sublease agreement.Tax practice also confirms that having several sole proprietors at one address is not, by itself, a violation and may be a lawful way of doing business without creating a legal entity. At the same time, fiscal authorities carefully examine such cases for signs of “business splitting” and hidden employment relations, which creates additional risks for entrepreneurs. Mandatory formalities for each sole proprietorIf several sole proprietors work in one booth, each of them must:file form No. 20‑OPP, indicating the shared address as their own place of business;have their own lease agreement (or other legal title) for use of part of the retail space or the entire premises;use their own cash register/POS (if required for the type of activity) and hold a separate licence for excisable goods;possess their own source documents for the goods and keep separate income records.Only under these conditions can the tax authorities recognise that several independent business entities operate at one retail spot, rather than a single “split” business. Staff and cash register: key risk areasThe most sensitive issues are staff and the organisation of settlements. If only one salesperson works at the point of sale and actually sells goods on behalf of two sole proprietors, the risks include:recognition of undeclared employment (when the salesperson is formally employed by only one entrepreneur but sells goods for both);additional tax assessments and penalties for hidden labour relations, as well as claims that the structure constitutes “business splitting” to reduce the single tax.From the regulators’ point of view, it is safer when each sole proprietor has separate employees, or the same salesperson is officially employed by several entrepreneurs at once (under different employment contracts and payrolls). It is also crucial to clearly separate goods and cash discipline: one cash register — one sole proprietor, separate receipts, separate reports. Single‑tax group and sales formatFor sole proprietors in group 1 of the single tax, additional restrictions apply: they may trade only from market stalls and may not use hired staff. If the “booth” is located at a market and officially registered as a retail place, several sole proprietors may work there, but each must comply with the rules of their own tax group.For groups 2–3 and the general tax system, a shared address is less problematic, yet the tax authorities still analyse income levels, cost structure, staff and business management for signs of artificial splitting of one business into several sole proprietors. If they find evidence of a single management centre and unified business, they may reassess taxes under the general regime and apply anti‑avoidance rules. Joint activity as an alternative modelOne way to legalise a de facto “shared booth” is to conclude a joint activity agreement between the entrepreneurs without creating a legal entity. Such an agreement allows the parties to formally set out responsibilities: ownership shares, rules for distributing income and expenses, and management of staff and risks.Although the agreement itself does not necessarily have to be registered with the tax authorities, the parties must carefully record joint operations and income to avoid claims that they have created a hidden legal entity or misclassified payments. This model is better suited to long‑term partnerships where entrepreneurs genuinely pool resources rather than merely “splitting” the cash register to keep within single‑tax limits. Practical conclusions for entrepreneursSingle‑tax sole proprietors may trade in one booth or at one retail spot only as independent entities, with separate contracts, cash registers, staff and documentation for goods. The mere fact of a shared address is not illegal, but without proper formalisation the tax authorities may treat the situation as business splitting or undeclared employment, with all related financial and criminal consequences.If you have any questions or issues related to organising joint trading by several sole proprietors at one retail spot, arranging staff, choosing the single‑tax group or minimising the risks of “business splitting”, please seek tailored legal and tax advice — properly structuring your business model will protect you from fines and conflicts with the regulators. Author – Yuliia Popadyn, attorney in tax and housing law at the law firm “Legal Company ‘WINNER’. https://www.youtube.com/watch?v=N9Rdi6CWE1s

Потрібна допомога адвоката? Залишай заявку The story of the new notice of suspicion for Serhii Tupalskyi, former deputy head of the Kyiv City Customs, has become another telling episode in the fight against corruption in agencies responsible for monitoring trade flows and customs payments. According to investigators, while holding a senior position at customs he accumulated assets that significantly exceeded his official income and the wealth of his family. To give these funds a legitimate appearance, he allegedly invested more than 2 million US dollars in cash in the construction of a restaurant and hotel complex on the territory of the Bukovel resort in the village of Polianytsia, Ivano‑Frankivsk region.The essence of the alleged offence lies not only in the existence of “excess” money of unknown origin but also in the mechanism of its subsequent laundering. Cash injected into a construction project is converted into a real‑estate asset with a clearly determined value, documented ownership rights and officially declared income from its operation. Once the hotel complex is commissioned, it begins to generate profit that appears entirely lawful, even though the original source of financing, according to the investigation, has a criminal origin. It is precisely this chain of actions that is described in the suspicion notice to Tupalskyi as the legalization of property obtained by criminal means.For anti‑corruption bodies, the case is important because it illustrates a typical scheme for transforming officials’ “shadow” income into a profitable tourism business. Former customs officers, judges, police officers and other officials traditionally like to invest in hotels, restaurants or apartments in popular resorts: it is easier to explain the source of income by referring to a “successful business” rather than hidden arrangements in public office. In the case of the Bukovel complex, the size of the investment, according to investigators, clearly does not correlate with the suspect’s official income, which became the starting point for the inquiry.Law‑enforcement agencies also focus on the ownership structure and the formal distancing of the official from the asset. In such cases property is usually registered in the names of close or distant relatives, or business partners who are not formally linked to the public official. However, control over the asset remains with the official: he makes key decisions, finances construction, and receives part or all of the real income. If investigators manage to prove such de facto control over the hotel complex, the chain “illicit funds — investment — property registered to a relative — legal income” may form the basis for a conviction.This suspicion did not arise in an information vacuum: Tupalskyi’s name had already appeared in several corruption scandals related to customs, cargo delays and possible “grey‑and‑black” import schemes. For law‑enforcement agencies, the current episode is a logical continuation of investigations that try to trace the path of funds from the moment of their potentially illegal acquisition (for example, through unofficial payments from businesses for “loyalty” at customs) to their final legalization in premium‑segment assets. For society, the case illustrates how corruption risks in border‑control agencies are transformed into expensive leisure and tourism facilities.From a legal standpoint, suspicion of laundering property obtained by criminal means is classified as a serious offence in the sphere of official and economic crime. It is important to understand that the law punishes not only the acquisition of “dirty” money but also any active steps aimed at giving it a lawful appearance: investing, purchasing assets, entering into sham contracts or re‑registering property in the names of front persons. That is why investigators focus not only on the origin of Tupalskyi’s funds but also on every legal step that accompanied the construction and launch of the hotel complex in Bukovel.For the Carpathian tourism market this story is also significant. It shows that some expensive infrastructure facilities may be financed not so much through transparent entrepreneurship as through converting corruption proceeds into “white” business. This creates unequal competitive conditions for bona fide investors who must raise loans, undergo financial monitoring and report publicly to banks and regulators. If law‑enforcement bodies consistently bring such cases to conviction, it may become a deterrent for officials who view resort real estate as a safe “offshore” for their undeclared income.Equally important is the signal for the customs service itself. Customs has long been one of the most corruption‑prone agencies, where every decision can carry a high price for importers and exporters. When the head or deputy head of a customs office finds himself at the centre of a case involving the legalization of millions of dollars, this calls into question the integrity of the entire control system and forces the state to look for new transparency tools: from staff rotation to process automation and stronger financial monitoring.At the same time, the presumption of innocence must be remembered: a notice of suspicion is not yet a conviction. To hold the former official criminally liable, investigators and prosecutors will have to prove not only the illegal origin of the funds but also a convincing link between this money and the specific hotel project, identify the real beneficial owner of the business and show the court that all the operations formed part of a single money‑laundering scheme. The quality of this body of evidence will determine not only the fate of one former official but also public perceptions of the effectiveness of the anti‑corruption system as a whole. If you have questions or issues related to allegations of asset legalization, money‑laundering risks or inspections by anti‑corruption bodies, it is advisable to seek timely individual advice from a lawyer . Author: Ihor Yasko, Managing Partner at WINNER Law Firm, PhD in Law. https://www.youtube.com/watch?v=N9Rdi6CWE1s

Потрібна допомога адвоката? Залишай заявку The White Business Club in Ukraine’s wartime reality is no longer just an “honour roll of champions” but an important element of the new architecture of tax administration. From 2026 the rules for forming the Club have changed significantly: lawmakers and the tax service are trying to turn it into a practical tool of trust that both rewards compliant taxpayers and allows the state to focus control resources on genuinely risky taxpayers. What the White Business Club is nowIn essence, the White Business Club is a list of taxpayers with a high level of voluntary compliance with tax legislation, formed automatically by the State Tax Service on the basis of objective indicators. Its creation is linked to the adoption of a special law on taxpayers with a high level of tax discipline, which defined the mechanism for forming the List, the selection criteria and the tax “bonuses” for companies that are included.Membership in the Club does not require an application — a taxpayer does not “join” but is included in the List if they meet the requirements monitored through reporting and the tax authority’s information systems. Being on the list brings a number of advantages: a lower likelihood of audits, simplified administrative procedures, faster communication with the tax authorities and greater predictability in relations with fiscal bodies. Changes effective from 2026From 1 January 2026 the rules for forming the White Business Club List were updated: rigid and often opaque criteria were replaced by a clearer model combining basic requirements (no tax arrears, disciplined reporting) with sectoral indicators of tax payments, while the List itself is updated regularly and the criteria can be adjusted in line with economic conditions and the realities of martial law. New requirements and criteria for taxpayersAll taxpayers seeking “white” business status must meet a set of universal requirements: have no significant tax debt, file returns on time, not be involved in major tax disputes and properly disclose information about their ultimate beneficial owners. Late filing is tolerated only within the limits of minimal penalties and if quickly remedied, giving a compliant company a chance not to drop out of the List because of a technical error.A separate block of criteria concerns the level of tax payments — corporate income tax, VAT and overall tax burden. The idea is simple: a company must show budget contributions that are not lower, and often higher, than the sectoral average in its region over a specified period. Different approaches are set for different categories of taxpayers (ordinary legal entities, individual entrepreneurs on the general regime, Diia City residents); for Diia City residents the key indicator is the overall level of taxes paid to the consolidated budget compared with the average for this group. Forming the List: what changed in the mechanicsThe key change is the absence of a “manual mode”: the List is formed by the tax service itself based on analysis of tax returns and information systems, and each update automatically replaces the previous version. This means businesses do not submit separate applications but must build their tax behaviour so as to meet the benchmarks throughout the period.At the same time, the tax authority may refine a taxpayer’s sector classification and apply criteria with regard to the specifics of their activity, such as revenue structure, geography of operations or staff numbers. For individual entrepreneurs on the general regime there are separate requirements for minimum staff size, intended to encourage legal employment and bring small businesses out of the shadows. Benefits of membership: why it matters for businessThe main benefit of being in the Club is more predictable relations with fiscal authorities and a reduced control burden. Members face fewer full‑scale audits, benefit from simplified administration of certain taxes and enjoy faster handling of their requests and submissions.Beyond the purely tax dimension, “white” taxpayer status becomes a reputational asset: banks, investors and counterparties increasingly consider information about a taxpayer’s compliance record, including based on official lists. For businesses this can mean better financing terms, a higher level of trust from partners and easier compliance checks in large corporate groups. Risks and the “flip side” of the new rulesStricter criteria will make it harder for some companies, especially low‑margin or highly seasonal ones, to remain on the List, and increased scrutiny of ownership structures plus broader grounds for audits mean that Club membership does not guarantee immunity from control. What businesses should do nowTo join the Club or keep their status in 2026, companies should verify that they have no tax debt, maintain disciplined reporting and up‑to‑date beneficial ownership data, analyse their own tax burden against the sectoral average, document their business model and integrate the Club’s criteria into their internal tax‑control system and finance team KPIs.If you have questions or issues related to the White Business Club, assessing compliance with its criteria or mitigating the risk of losing your status, it is advisable to seek individual advice from a specialised tax consultant or lawyer. Author – Maksym Bahniuk, Head of Tax and Customs Law Practice at WINNER Law Firm. https://www.youtube.com/watch?v=N9Rdi6CWE1s

Потрібна допомога адвоката? Залишай заявку The State Tax Service is changing its approach to blocking VAT invoices: instead of a purely punitive model it is introducing a preventive tool — “roadmaps” for VAT payers that explain how to complete and submit the Data Table in order to minimise the risk of automatic blocking.Why blocking VAT invoices remains a problemThe SMKOR risk‑monitoring system blocks VAT invoices based on formal criteria such as mismatched business activity codes, lack of stock, “risky” counterparties, sharp jumps in volumes or technical errors. For businesses this means broken supply chains, the buyer losing input VAT credit and funds being frozen. Although, according to the tax service, the share of blocked invoices has been reduced to 0.1–0.15% of all registrations, in absolute terms this still represents thousands of documents, especially in sectors with many small‑value transactions.Essence of the new tool: roadmaps for the Data Table· The tax service is focusing on the VAT Taxpayer Data Table, which shows a business’s typical purchases and sales; once the Table is accepted, most transactions can be registered without suspension.· Common issues include the Table not being filed at all or being filled in only formally, without a description of the business model, references to reporting or reflection of the enterprise’s real resources.· Based on typical mistakes and business feedback, the tax service has developed step‑by‑step roadmaps for specific types of activity.· These instructions explain how to describe business operations and link customs and service codes to real‑life transactions.· They list which contracts, reports and accounting data should be cited in explanations.· They show which indicators for staff numbers, fixed assets and wages look suspicious to the tax authority.· The purpose of the roadmaps is to translate the “language” of SMKOR into clear instructions for business so that companies can correctly present the tax reality of their operations and their typical economics.Most common errors leading to rejection of the Data TableAlongside the launch of the roadmaps the tax service has published a list of the most frequent mistakes that cause the Data Table not to be accepted:– submitting the Table with no explanation of the taxpayer’s activity;– explanations that contain no description of business operations and no references to reports, contracts or primary documents;– too few employees or wages that are too low for the declared volumes of work;– discrepancies between information in the Table and data from automated systems (the VAT invoice register, reporting, stock data and the taxpayer’s compliance history).Taxpayers often treat the Table as a mere formality, whereas for SMKOR it is the key source of information about their “normal” business model. The new tool is meant to encourage businesses to complete this document not just for the sake of form, but as a strategic element of tax security.How the roadmaps are intended to reduce blocking riskIn the tax service’s concept, the roadmaps should function as a checklist for accountants and owners: if the Table is completed according to the recommended logic, the risk of blocking is significantly reduced. The idea is to:– eliminate technical errors (incorrect codes, incomplete explanations, lack of links to reporting);– align the activities shown in the Table with business‑activity codes, staffing levels and accounting data;– explain to the tax authority the economics of a typical transaction in the relevant sector (construction, agriculture, transport services, fuel trading, etc.).As a result, SMKOR receives a higher‑quality data set on the taxpayer and triggers less often on “formal risk”, where the business is not actually breaking the law but looks suspicious because of inaccurate information filing.Limitations and risks of the new approachDespite the positive signal, the new tool does not resolve every issue: SMKOR’s risk criteria remain opaque, and acceptance of the Data Table does not rule out blocking in cases of sharp volume changes or dealings with “risky” counterparties. For complex business models the roadmaps are only a starting point, so individual analysis and professional support are still needed.How businesses can use the roadmaps in practiceFrom a tax‑risk‑management perspective the new tool should be seen as an opportunity to organise relations with the tax service and at the same time carry out an internal audit of VAT processes. It is useful to: analyse your own invoice‑blocking cases over recent years — which product codes, counterparties and volumes caused the most problems; compare these cases with the roadmap recommendations for your sector and identify what needs to be improved in the Data Table and explanations; update activity codes, HR data and information on fixed assets so they do not contradict the activities declared in the Table; build an internal checklist so that, before submitting a new Table or large VAT invoices, you verify consistency between accounting data, reporting and your electronic taxpayer cabinet.This approach not only reduces the risk of blocking but also makes the business more transparent to supervisory bodies, which, under increasing fiscal pressure, can become a competitive advantage. ConclusionThe launch of the tax service’s roadmaps is a step towards more predictable interaction with VAT payers and should reduce the number of blockings caused by basic mistakes and misunderstandings. At the same time, it is not a magic “anti‑blocking button”: companies, especially in high‑risk sectors, must still carefully monitor their counterparties, document quality and data consistency across all systems.If you have questions or difficulties related to blocked VAT invoices, completing the VAT Taxpayer Data Table or appealing tax‑authority decisions, you should seek advice from tax consultants and legal professionals in order to choose an optimal defence strategy and minimise risks for your business. Author – Maksym Bahniuk, Head of Tax and Customs Law Practice at WINNER Law Firm. https://www.youtube.com/watch?v=N9Rdi6CWE1s

Потрібна допомога адвоката? Залишай заявку The specialised Tax Committee of the Verkhovna Rada has approved tax changes on the taxation of income from digital platforms and the abolition of the tax exemption for parcels up to 150 euros, shaping a new system of control over the online economy that will operate mainly from 2027.What has been decided on digital platformsThe Committee supported the revised government bill No. 15111 on the taxation of income received through digital platforms — marketplaces, online rental services, work‑for‑hire and freelance platforms, and similar services.The main idea is to introduce in Ukraine a model close to OECD standards and the EU DAC7 directive, where the platform operator becomes a tax agent and withholds taxes from payments to individuals.Key parameters of the new regime:– personal income tax rate of 5% instead of the standard 18% on income of individuals earned via digital platforms, plus the existing military levy;– the tax agent is the platform itself: it must identify sellers, collect information about their income, withhold PIT and the military levy and transfer them to the budget;– international automatic exchange of information on income from platforms is introduced in line with OECD and EU (DAC7) standards, which implies data exchange with other jurisdictions. Importantly, after revisions several of the most controversial provisions that had triggered resistance from business and lawyers were removed:– the requirement for sellers using platforms to open special bank accounts was abolished;– the idea of mandatory disclosure of banking secrecy for all platform‑related income was dropped;– instead of mandatory filing of tax returns when thresholds are exceeded, the tax service will send the taxpayer a tax notice‑decision — essentially a “pre‑filled calculation” based on data received from platforms. Self‑employed individuals and sole proprietors will be allowed, if they wish, to tax platform income under the general rules rather than under the special 5% model, which removes the risk of double accounting for active entrepreneurs. When will the “platform tax” start working?Despite the public outcry, none of the new tax bills will bring money to the budget already in 2026. The new regime for digital platforms is tied to technically complex international data exchange, so the bill itself includes deferrals:– formally, the rules are to take effect from 1 January 2027;– in practice, the launch will be possible only after international data‑exchange agreements are signed and the IT systems are technically ready;– experts and MPs predict that actual tax assessments based on platform data will not occur before 2028 (based on reporting for 2027). Thus, 2026 will be a “transition” year: the legal framework and infrastructure will be prepared, but mass payments will appear later. New obligations for marketplaces and platforms– Identify all sellers (individuals and legal entities) earning income via the platform.– Annually, by 31 January, submit to the tax service a report with data on users’ income, number of transactions, country of tax residence, and so on.– Store information on transactions and be prepared to transmit it within the framework of international automatic exchange.– Global services must adapt to Ukrainian requirements in addition to DAC7 and other countries’ rules.– Local platforms must invest in IT accounting, KYC/KYB procedures and legal support, which will raise the barrier to entry but weed out openly “grey” marketplaces. What will change for ordinary platform usersFor typical small sellers and freelancers the main effect will be the legalisation of income taxed at 5% without having to file returns: the platform itself will withhold tax from payouts. At the same time, the space for “black” sales will shrink: thanks to data exchange the tax service will see the volume of transactions via platforms, so active sellers will either formalise their activity or risk additional assessments after future audits. Parcels up to 150 euros: is the exemption ending?The Committee has supported at first reading the alternative bill No. 15112‑1 abolishing the exemption for duty‑free parcels up to 150 euros, which the government expects could bring up to 10 billion hryvnias in additional revenue. However, the changes are not final: the bill still needs revision, technical amendments to the Customs Code and possible adjustments to thresholds and rates. How parcels may be taxedWhile detailed mechanisms differ between draft versions, the overall logic is clear:– any parcels from abroad may become subject to VAT and possibly customs duty from the first euro of value, without today’s 150‑euro “safety cushion”;– key parameters (value threshold, list of exceptions, procedure for calculating and collecting payments) will be set out in the Customs Code;– the government and the Committee emphasise that the parcel‑delivery process for the customer will formally remain unchanged: the logistics company will still deliver it to a pick‑up point or address, while taxes will be embedded in the item’s price and paid via the platform or customs broker. For major international marketplaces this may mean a shift to a model where VAT and duty are charged already at the order‑checkout stage, with the platform acting as an intermediary between the buyer and the tax authorities. What this means for consumers and businessFor Ukrainian consumers, the end of the exemption will make small online orders from foreign sites more expensive due to VAT and possible customs duty, especially in niches where there are no cheap Ukrainian alternatives. For small importers it means lower margins and the need to operate more formally, while official imports and local retail will gain an advantage because competition from “grey” duty‑free parcels will weaken. Political and fiscal contextThe package of bills on digital platforms, parcels and the military levy is part of Ukraine’s commitments to the IMF and therefore has not only fiscal but also political significance. Experts warn that the actual budget effect may fall short of expectations, and excessive pressure on small business without moderate rates and simple procedures will only encourage new avoidance schemes. The success of the reforms will depend on the quality of parliamentary revisions and on implementing regulations by the tax and customs services, since tighter control is meant both to adapt the

Потрібна допомога адвоката? Залишай заявку Members of the Verkhovna Rada propose introducing personal financial liability for Territorial Recruitment Centre (TRC) staff and criminal liability for doctors who issue unlawful fitness‑for‑service conclusions. In March 2026 a bill was registered that strengthens liability for TRC officials for illegal decisions and for Military Medical Commission (MMC) doctors for knowingly false conclusions. The initiative is a response to numerous cases of bribery and falsification in the mobilisation system, which have undermined public trust in the country’s defence structures. Core provisions of the billTRC employees will bear financial liability: from fines to an obligation to compensate losses if their actions or inaction led to unlawful decisions or exemptions from mobilisation.Members of military medical commissions will face criminal liability for knowingly false medical conclusions on fitness for service.The internal control units within TRCs will gain broader powers, including initiating disciplinary proceedings and forwarding materials to the State Bureau of Investigation and the Prosecutor’s Office.Unlawful actions by TRC officials or medical staff aimed at helping citizens evade mobilisation will be treated not as mistakes but as intentional crimes against the state’s defence capability. Reasons for the initiativeUkraine’s mobilisation system during the war with Russia has repeatedly been criticised for opaque decision‑making, corruption schemes and a lack of real accountability for abuses. Since summer 2023 law‑enforcement bodies have recorded dozens of cases where citizens, in exchange for bribes, illegally obtained certificates of unfitness, avoided conscription or left the country using forged documents. The bill’s authors stress that disciplinary sanctions alone do not deter offenders and that the absence of clear financial and criminal liability has created fertile ground for corruption, so new mechanisms must ensure the inevitability of punishment. How offenders are to be punishedFinancial liability for TRC employees will cover both bribery and negligence: if the state suffers losses, they must reimburse them from their own funds. For doctors, amendments to the Criminal Code are proposed: intentional falsification of medical conclusions would be punishable by 3 to 8 years’ imprisonment and a five‑year ban on holding medical positions. Where doctors, intermediaries and TRC staff participate in organised schemes to circumvent mobilisation, they would be treated as accomplices to a crime against national defence. Parliament and public reactionThe initiative is being discussed in relevant committees on national security and law enforcement. Some MPs support the bill as a step towards cleaning up the mobilisation system and restoring trust. At the same time, MPs and human‑rights advocates warn that excessively broad punitive powers may lead to new abuses, with doctors and TRC staff afraid of even honest mistakes because of the risk of criminal prosecution. They emphasise the need to clearly distinguish intentional misconduct from professional error so as not to create an atmosphere of fear in a system that requires confidence and stability. Expert assessmentLawyers and military‑law specialists generally view the introduction of personal liability positively, arguing that collective impunity in state institutions inevitably breeds systemic corruption. When an official realises they may have to pay out of pocket or go to prison, their behaviour changes dramatically. However, experts note that the effectiveness of these reforms depends not only on the legal text but also on the quality of investigations and court practice: if law‑enforcement and courts continue to avoid real sentences for high‑level officials and focus only on “small fish”, even the toughest sanctions will have limited impact. Impact on the TRC systemIf adopted, the bill will trigger a review of TRC internal procedures. Staff will have to log all actions in electronic registers, and decisions on deferrals, exemptions or findings of unfitness will be taken collectively, with digital signatures of responsible officials. This should make it possible to identify exactly who made an unlawful decision or approved forged documents. The Ministry of Defence is expected to create an internal financial‑disciplinary tracking system where all violations are recorded in personal files, helping build anti‑corruption statistics and reducing the risk of repeated offences. Risks for the medical communityDoctors broadly support stronger accountability but fear that the new rules may complicate the work of military medical commissions, since fitness assessments often lie on a borderline and rely on expert judgement. If such decisions could trigger criminal charges, doctors may choose “safer” but not always fair conclusions. For this reason the medical community insists on clear criteria for intent — such as proven receipt of illegal benefit, document falsification or a lack of any objective medical justification for the conclusion. Possible effects on the mobilisation systemIntroducing personal and criminal liability has a dual effect: it increases discipline and narrows the space for illegal schemes, but it also risks over‑bureaucratising the system and slowing mobilisation processes in critical periods. Anti‑corruption initiatives in the military sphere always balance control against efficiency, and Ukraine is effectively betting on personal liability as the main deterrent, following examples from NATO countries. Conclusion:The proposed bill is another step towards cleaning the mobilisation system of abuses and corruption, but its success will depend on finding a balance between inevitable punishment for offenders and workable conditions for conscientious staff. If you have questions or problems related to medical commissions, dealings with TRCs or challenging unlawful actions by officials, you should seek advice from lawyers specialising in military and administrative law. Author – Svitlana Krutorohova, attorney at the law firm “WINNER”. https://www.youtube.com/watch?v=N9Rdi6CWE1s

Потрібна допомога адвоката? Залишай заявку Ukraine’s real estate market is bracing for new changes intended to make housing transactions more transparent and subject to tighter state oversight. The government and tax authorities are stepping up monitoring of property sales and rental deals, citing the need to combat tax evasion, shadow income and money laundering. For businesses, real‑estate agents and ordinary citizens this will mean more reporting and greater administrative burdens, while the state expects higher budget revenues and better control over illegal income. Fiscal motives: why control is tighteningThe main driver of these reforms is the need to shrink the shadow rental market, where a large share of contracts are informal and only a fraction of landlords pay tax. In wartime and reconstruction conditions this translates into billions in annual losses, so real estate has become a key target for enhanced oversight. The logic is straightforward: anyone earning income from owning housing should pay tax on it just like any other taxpayer. New control toolsAuthorities plan to expand data exchange between state registers, giving the tax service direct access to the register of property rights, notarial registers and bank transaction databases, allowing deals to be tracked in real time. An electronic register of residential lease agreements will be created, into which all written contracts must be entered with details of the parties, rent amount and term. For sale‑purchase transactions, identification of parties via BankID or qualified e‑signature will be strengthened, and notaries will be obliged to notify the tax service of every transfer of real estate ownership simultaneously with entering the record into the State Register of Rights. Impact on the rental marketThe rental segment is traditionally viewed as the “greyest” part of the real‑estate market: many owners rent out properties without contracts or use sham short‑term agreements to avoid taxation. The new mechanisms are meant to bring this segment out of the shadows. Once electronic registration of leases and stricter bank monitoring are introduced, cash circulation in rentals is expected to decline, making it harder for landlords to hide income and giving tenants stronger legal protection: a formal contract will help prove lawful occupancy, recover deposits and resist unjustified evictions. Experts, however, warn that some owners may temporarily withdraw their properties from the rental market to avoid higher tax burdens, which could reduce supply and push up rents, especially in major cities. How sales will be monitoredFor purchase and sale of housing, income declaration becomes central. The tax service is developing an algorithm to automatically compare the contract price with market values for similar properties in the region; if the price is significantly lower, the transaction will be flagged as high‑risk. Banks will also take on a larger role, as they must report suspicious transactions involving large sums or regular activity on individuals’ accounts. In the longer term the state plans to restrict all‑cash payments, so transactions above a certain threshold (likely 200–300 thousand UAH) can be settled only via bank accounts, making money flows more transparent and reducing the risk of laundering funds through real estate. Market and professional reactionReal‑estate agents, developers and notaries react ambivalently: greater transparency strengthens legal certainty, but extra bureaucracy may slow paperwork and increase service costs. Market participants warn that excessive fiscal pressure could push some owners toward off‑the‑books schemes, yet most experts agree that, in the long run, a transparent market reduces legal risks and boosts confidence in housing investment. International experienceUkraine is moving closer to European practice, where tax control in real estate is standard. In Poland all rental contracts must be registered and tax of about 8.5–12.5% is paid automatically via an online return. Italy uses the “Cedolare secca” regime, which offers simplified taxation of rental income provided the lease is officially registered. For Ukraine such an approach could serve as a transitional step if the state introduces preferential tax rates for those who declare rental income officially for the first time, encouraging legalisation without excessive fiscal shock. Legal risks and future trendsTighter control may lead to more court disputes, especially where tax authorities assess additional liabilities based on indirect income indicators or market values, so lawyers recommend careful contract drafting, keeping payment records and avoiding “grey” cash settlements. Policymakers are also discussing electronic real‑estate declarations for individuals, which would allow automatic detection of discrepancies between tax returns and register data. Economists expect that greater transparency in the property market will strengthen macro‑financial stability, while legalising the rental segment could add more than 10 billion UAH to the budget annually. ConclusionStrengthening state control over housing sales and rental transactions is an inevitable stage in Ukraine’s economic development. Despite short‑term difficulties for market participants, it should ultimately reinforce the rule of law, shrink the shadow sector and increase trust between citizens and public institutions. If you face questions or issues related to taxation, rental contracts or legalising real‑estate income, it is advisable to consult tax and legal professionals to find the best solution for your situation. Author – Svitlana Krutorohova, attorney at the law firm “WINNER”. https://www.youtube.com/watch?v=N9Rdi6CWE1s

Потрібна допомога адвоката? Залишай заявку The State Tax Service of Ukraine has published an updated schedule of documentary audits for 2026, which includes 1,016 individuals. For wealthy citizens and active sole proprietors this is a clear signal of tighter tax control and increased attention to their income in 2026. What is a schedule of documentary auditsA schedule of documentary audits is the official list of taxpayers that the tax authority plans to audit during the year. It is formed using a risk‑based approach: it includes taxpayers with increased risks of tax non‑payment or abuse (high income volumes, sharp financial fluctuations, transactions with non‑residents, work with “risky” counterparties, tax debts, etc.).Planned documentary audits of individuals involve a detailed review of primary documents, contracts, bank statements, asset and income declarations and data from state registers. They are carried out at the taxpayer’s place of registration and usually cover several tax periods. Why individuals are in focusThe fact that the State Tax Service separately plans to audit 1,016 individuals shows growing attention to citizens’ income that does not always pass through the classic business segment. This primarily concerns: individuals with high declared or actual income (rent, sale of real estate, investments, securities transactions); sole proprietors with significant turnover who may be audited both as entrepreneurs and as private individuals; persons whose expenses (purchase of property, cars, luxury assets) significantly exceed their officially declared income; persons involved in other audits or criminal proceedings where potential tax violations have been identified. In recent years the state has been moving towards a model where an individual’s financial behaviour is analysed comprehensively: through tax reporting, banking data, information from public registers (real estate, vehicles) and international tax information exchange (CRS/EOIR for certain jurisdictions). How individuals are selected for auditInclusion in the schedule is not random. Individuals are added to the list of potential audit targets mainly on the basis of: analysis of filed tax returns: mismatch between income and type of activity, unusual or sharp year‑to‑year changes; data on major assets: purchase of expensive housing, cars or business assets with relatively modest declared income; information from banks and other institutions: significant movements of funds on accounts, regular inflows from abroad, securities and derivatives transactions; results of audits of counterparties: if a corporate audit reveals suspicious transactions with an individual, this may trigger their inclusion in the schedule; participation in risky schemes, such as splitting business across several sole proprietors, sham civil contracts instead of employment contracts, etc. Thus, the updated 2026 schedule should be seen as the result of prior risk analysis rather than a “random sample”. What will be audited for individuals· Declaration of income from rental of residential and commercial property and land.· Timeliness and completeness of payment of personal income tax, military levy and social contributions (for sole proprietors).· Real estate transactions: frequency of sales, market‑level prices, use of tax exemptions.· Foreign income and transactions: salaries, dividends, interest, royalties, crypto transactions and foreign accounts.· Investments: transactions with shares, bonds, corporate rights and startups.· Consistency of lifestyle with officially declared income (major purchases, travel, expenses). Potential consequences for taxpayersFor individuals included in the schedule, an audit may lead to: additional tax assessments (personal income tax, military levy, social contributions) if underreporting or concealment of income is found; fines and late‑payment interest for incomplete or late tax payments; initiation of criminal proceedings where the amount of tax evasion is significant or deliberate schemes are detected; blocking of certain transactions, freezing of bank accounts or assets as part of criminal or enforcement procedures. At the same time, for compliant taxpayers an audit may end without negative consequences, but it will still require time, document collection and professional support. Risks of informal activity and “cash” schemesThe updated 2026 schedule targets informal economic activity by individuals who earn systematically but do not register as entrepreneurs and do not declare income. This includes:· unofficial provision of services (consulting, IT, creative, educational);· continuous rental of housing or commercial premises without formal contracts;· systematic online trading without registering as a sole proprietor;· use of cryptocurrencies and electronic payment systems to “anonymise” income. As digitalisation and data exchange grow, the belief that cash and online payments will remain invisible is increasingly unrealistic: the tax service builds risk profiles and analyses taxpayer behaviour. How to prepare for possible auditsReview your tax history for the last 3–5 years: completeness of income declaration and payment of personal income tax and the military levy.Check rental, sale‑purchase and investment contracts and ensure you have supporting documents for all major transactions.Organise bank statements and primary documents (acts, invoices, delivery notes, certificates, receipts).If you are self‑employed or a sole proprietor, make sure your tax regime matches your real turnover and types of activity.If you have foreign income or accounts, assess your tax obligations in Ukraine, considering double‑tax treaties.If you are a business beneficiary, analyse risks of transactions with related companies, intra‑group loans, dividends and financial assistance. What this trend means for 2026The updated schedule and explicit number of individuals planned for audits show a clear trend: the state is shifting from focusing only on businesses to deep monitoring of private finances. This aligns with global practice, where the fight against shadow income, money laundering and aggressive tax planning targets not only companies but also ultimate beneficial owners — individuals. For citizens this means that “personal” financial behaviour will increasingly be viewed through the lens of tax transparency. Those who proactively organise their documents, declare income and think in terms of tax planning rather than “minimisation at any cost” will be in a better position. If you have questions or issues related to audits by the State Tax Service, additional tax assessments, legalisation of income or preparation of documents for tax control, it is advisable to consult tax law and advisory professionals to minimise risks and protect your interests. Author: Ihor Yasko, Managing Partner at WINNER Law Firm, PhD in Law. https://www.youtube.com/watch?v=N9Rdi6CWE1s

Потрібна допомога адвоката? Залишай заявку According to the State Tax Service, Ukrainians who earned income from posting content on OnlyFans in 2020–2022 already “owe” the state 384.7 million UAH in taxes. The tax authorities actively use information exchange with foreign agencies, receive data from Fenix International Ltd and massively assess additional personal income tax and military levy. For models and other creators this means audit reports, tax notices‑decisions, risks of account freezes and even criminal proceedings for tax evasion. At the same time, the system still thinks in terms of a “classic” taxpayer: salary or sole proprietor, hryvnia accounts in a Ukrainian bank, straightforward contracts. The reality of OnlyFans is a foreign platform, foreign currency, payment services, cryptocurrency, expenses abroad and P2P transactions, where the state sees only part of the operations. In response, the tax service often chooses the most primitive approach: it takes the total from a foreign statement and calculates taxes “to the maximum” without analysing what the particular taxpayer actually received. Our case: an OnlyFans model vs. the tax authoritiesWINNER Law Firm specialises in tax and administrative disputes, including for individuals, entrepreneurs, creators and business owners. Our practice includes a case of an OnlyFans model to whom the STS assessed substantial additional personal income tax and military levy, relying solely on information from a foreign tax authority and aggregated payout figures. We built the defence on three key pillars: first, the lack of proper evidence that the entire stated amount was in fact received by the client as taxable income; second, significant violations of the audit procedure and the way its results were recorded; third, incorrect application of the Tax Code provisions to foreign income and limitation periods for additional assessments. The court agreed with WINNER’s position and cancelled the tax notices‑decisions, fully removing additional assessments and penalties from the client. This case shows that even in high‑profile topics such as OnlyFans, a taxpayer can defend themselves if they work with lawyers who understand both tax practice and the specifics of the new digital economy. From criminal cases to on‑site audits: what WINNER doesToday the tax authorities aggressively use the full toolkit of pressure: documentary and on‑site audits, fines, blocking of activities, and in complex cases criminal proceedings under tax articles. A typical story starts with a “standard” request or warning letter and ends with several years of additional assessments, frozen accounts, interrogation summons and the risk of criminal liability. WINNER Law Firm provides a full cycle of protection for businesses, sole proprietors and individuals: from consultations and risk analysis to audit support, challenging tax decisions in administrative and court procedures, and responding to searches, interrogations and other investigative actions. We help clients prepare for audits, minimise penalties, defend their rights in court and, where necessary, properly structure income from foreign platforms to reduce future risks. If you have received an audit report, a tax notice‑decision, a summons for interrogation or an information request regarding income from OnlyFans or other foreign sources, you should not face it alone. Contact WINNER Law Firm to build a timely strategy from the “first letter” to the final court decision and protect yourself from penalties, account blocks and criminal pressure. Maksym Bahniuk, Head of Tax and Customs Law Practice, and Yevhenii Murchenko, Head of Criminal Law and Procedure Practice at WINNER Law Firm. https://www.youtube.com/watch?v=N9Rdi6CWE1s