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What is a gift agreement.  A gift agreement is a contract under which the donor transfers property to the donee free of charge and does not require anything in return. The key features are gratuitousness and voluntariness; any compensation means it is no longer a gift in the legal sense. What property can be gifted.  Almost any property can be the subject of a gift agreement, except for assets with a special legal regime. Most often, the following are gifted:· apartments and houses;· land plots;· vehicles;· corporate rights and shares in the charter capital;· sums of money or securities;· movable property (household appliances, furniture, jewellery, etc.).Property withdrawn from civil circulation or seized by a court or state authorities cannot be gifted. Concluding a gift agreement.  The form of a gift agreement depends on the type of property. As a general rule, the agreement must be in writing, and in the case of real estate or vehicles it must be notarised. Real estateGifts of an apartment, house or land plot must be executed before a notary. After the agreement is signed, the notary registers the donee’s ownership in the State Register of Property Rights, and only after that may the new owner dispose of the property. Movable property (including cars)Gifting a vehicle also requires notarisation, because it is subject to state registration. Other movable property may be gifted in simple written form. Money or business sharesSuch agreements are concluded in writing and in some cases are subject to additional requirements (for example, corporate rights in an LLC require amendments to the Unified State Register). Key documents for execution.  In 2026 a notary will usually require:· passports and tax identification numbers of the parties;· documents confirming the donor’s title (sale and purchase agreement, certificate of inheritance, etc.);· a valuation report for the property (for real estate or vehicles);· an extract from the State Register of Rights or a cadastral plan (for land);· for gifts between relatives, documents confirming kinship (birth or marriage certificates, etc.). Who can be a party to the agreement.  Both individuals and legal entities may act as donor and donee. If the donor is an individual, he or she must have full civil capacity. Gifts on behalf of children or persons declared incapable are not allowed without the consent of guardianship authorities.Persons who hold property in joint ownership (for example, spouses owning an apartment) may gift it only with the consent of the other co‑owner, unless otherwise provided by law or a prenuptial agreement. Taxes on gifts in 2026.  One of the most important issues for the parties is taxation. In 2026 the tax rules continue to reflect the Tax Code of Ukraine, under which the tax treatment depends on the degree of kinship between the donor and the donee. Gifts between close relativesIf the parties are members of the first or second degree of kinship (parents, children, spouses, siblings, grandchildren, grandparents), the personal income tax rate is 0%. This means the donee pays no tax. Gifts between non‑relativesIn this case the donee pays 18% personal income tax and 1.5% military levy on the appraised value of the gift. This applies to all types of gifts, including real estate and vehicles. ForeignersIf the recipient is a non‑resident of Ukraine, the same rate applies — 18% plus 1.5%, regardless of kinship. Cost of notarisation.  The cost of a gift agreement in 2026 includes: Notarial fees.Depending on the region, complexity of the agreement and value of the property, fees may range from UAH 2,000 to 10,000 for real estate and from about UAH 1,500 for movable property. Administrative charges.State fees for registration of ownership are paid additionally — about 0.1% of the appraised value, but not less than UAH 30. Property valuation.For real estate and vehicles, a market valuation by a certified appraiser is required. The service costs from UAH 1,000 to 3,000. Other expenses.You may also need to pay for extracts from the State Land Cadastre or the State Register of Rights (about UAH 50–300) and for copies of documents. When an agreement can be invalidated.  A gift agreement may be challenged in court if:· the donor lacked legal capacity;· it was signed under duress or through deception;· there was no consent from a co‑owner;· the agreement was made to evade taxes or conceal another transaction.The donor may also withdraw from the agreement before the transfer of property or revoke the gift in cases expressly provided by law (for example, when the donee commits a crime against the donor or the donor’s family). Practical tips for 2026· Always check that the property is free from encumbrances or mortgages before gifting.· For newly built real estate, make sure the developer’s ownership is properly registered.· Use notaries experienced in gift transactions to avoid registration errors.· Keep proof of payment of all fees and taxes.· If you are gifting to a non‑relative, calculate the tax consequences in advance, as they may be significant.If you have questions or difficulties related to execution or taxation of gift agreements in 2026, consult a qualified lawyer or notary who will help you prepare the documents correctly and avoid financial risks. Author – Svitlana Krutorohova, attorney at the law firm “WINNER Legal Company”. https://youtu.be/cRQXdIrL4_g?si=O8ZGNtYSrBqnBjCd

Joint ownership is one of the most complex forms of rights to real estate. It simultaneously grants each co-owner a share in a common asset and imposes significant restrictions on the exercise of this right. Practice shows that conflicts most often arise when one of the co-owners tries to sell or donate their share without the consent of the others. The law formally allows this, but in reality the transaction frequently becomes impossible because of legal and practical barriers.​ Legal nature of joint fractional ownershipUnder Articles 355–367 of the Civil Code of Ukraine, joint fractional ownership means that each co-owner has a defined share in the ownership right to the property, while the property itself remains a single and indivisible object until it is divided in kind or a share is separated into an independent asset. This structure creates a duality: the rights of each party are legally regulated, but in practice use and disposal often overlap, which becomes a source of numerous conflicts, especially when a share is sold to a third party.​ Pre-emptive right of co-owners to purchaseThe key restriction is set out in Article 362 of the Civil Code, which establishes the co-owners’ pre‑emptive right to buy a share. If a co-owner decides to sell, they must notify the other co-owners in writing of the intention to sell, the terms of the transaction and the price, and for real estate the others have one month to decide whether to buy. This mechanism is designed to protect co-owners from outsiders entering the circle of joint ownership but at the same time significantly complicates the disposal of a share and often makes the deal practically unrealizable: delays in responses, artificial price manipulation or avoidance of receiving notices turn the right to sell into a purely theoretical option.​ Typical situations where selling a share is impossible No real division of the property: the buyer receives only an ideal (undivided) share with no clear use, which is practically unusable without consent from the other co-owners and economically unattractive. Conflict between co-owners: blocking access to the property and documents makes formalizing a transaction difficult and risky even if a buyer is found. Long litigation history: disputes, arrests or unclear rights discourage buyers, and banks usually refuse to finance such deals. Insignificant share (for example, 1/20 or 1/100): the sale is mostly formal, does not resolve use issues and the buyer cannot obtain a separate part in kind. Violation of the notification procedure: any co-owner may ask the court to recognize the buyer as a bad-faith acquirer and transfer the buyer’s rights to themselves, so notaries will often refuse to certify such transactions without impeccable proof of proper notice.​ Division in kind and compensationThe only reliable way to legally “free” one’s share is division in kind or allocation into a separate property unit. If this is technically possible (for example, part of a house with a separate entrance, a land plot, a garage), a co-owner may apply to court to have a specific part defined; after that the new unit is registered separately and its sale becomes straightforward. If division is impossible, the court may award monetary compensation for the share to be paid by the other co-owners, but this works only where they agree or the judgment sets a compensation amount; otherwise the owner remains a “hostage” of their share.​ Attempts to sell on the open marketA buyer looks for an asset that can be used in practice. Purchasing ½ or ⅓ of an apartment with unknown co-owners, no allocated rooms and no clear arrangements is an unjustified risk, so in practice there are almost no buyers for such shares. Sometimes alternative mechanisms are used, such as auction sales, gifts followed by division, exchange of a share for another asset or compensation, but all of them require careful legal support and still do not guarantee success.​ Conclusions: where law meets realityThe law grants a co-owner the right to dispose of their share, but this right is often conditional. When the object is effectively indivisible and the interests of the co-owners are in conflict, selling a share becomes almost impossible, and the real outcome is determined less by legal rules than by the balance of power between the parties. Therefore, before deciding to sell a share, it is important to assess the possibility of division in kind, review documents and disputes, duly notify all co-owners and involve a lawyer to structure and support the transaction. These steps may not speed up the process, but they significantly reduce the risk of future litigation.​ If you have questions or issues related to disposing of a share in joint property, dividing real estate or structuring the purchase of a share, you should seek individual legal advice to find a safe solution in your particular case.​ Author – Svitlana Krutorohova, attorney at the law firm “Legal Company ‘WINNER’”. https://youtu.be/cRQXdIrL4_g?si=O8ZGNtYSrBqnBjCd

New Labour Code is designed to replace the outdated Labour Code of 1971 and reset the rules of the labour market by combining stronger protection of employees with greater flexibility for business and EU‑integration standards. For employees, this will mean an updated set of guarantees, modern forms of employment, digitalised procedures and clearer mechanisms for protecting their rights, while for employers – simplification of HR processes, more transparent rules for formalising employment relations, but also increased liability for violations.​ Why a new Code is neededThe current Labour Code, adopted back in Soviet times, is only partially adapted to the modern economy, digitalisation and flexible employment, and therefore does not correspond to today’s labour‑market realities. The new Labour Code is being developed as a framework instrument for post‑war recovery, European integration and harmonisation with ILO conventions and EU law, with the aim of balancing the interests of employees and employers.​ The labour‑law reform is part of Ukraine’s commitments under the Association Agreement with the EU and memoranda on labour‑market reforms. Its logic is a shift from an overly regulated, formalistic model to a flexible but protected labour market with a stronger role for social dialogue.​ Key novelties for employeesClear consolidation of the right to decent work, non‑discrimination, equal opportunities and protection against unfair dismissal, an expansion of occupational‑safety guarantees and tools against mobbing and discrimination, as well as more detailed mechanisms for compensation of damage.​ Systemic regulation of flexible forms of employment: remote and home‑based work, flexible schedules, temporary and seasonal contracts, traineeship agreements and work of domestic workers, with clear guarantees of pay, working time and rest.​ An updated list of types of leave (annual, social, educational, unpaid), aligned with European standards of duration and flexibility, giving more opportunities to plan work and personal time and strengthening protection of specific categories of workers.​ What will change for employers Simplified procedures for conclusion, amendment and termination of employment contracts, unification of processes and transition to electronic HR document flow; broader use of standardised contracts, local policies and internal regulations.​ Greater flexibility in pay systems, bonuses, shift schedules, remote work and other modern formats of work organisation, provided employees are properly informed and minimum guarantees are respected.​ A stronger role of labour inspection: broader powers for control, access to documents and response to violations, which increases the risk of sanctions where “shadow” employment schemes are used.​ The need to revise policies on remote and home‑based work (working time, reimbursement of expenses, health and safety at remote workplaces, performance control).​ Alignment of labour practices with European compliance standards, reducing legal risks for employers engaged in cross‑border projects.​ Digitalisation and the new role of inspectionsThe new Labour Code is integrated with the digitalisation of labour relations: electronic employment record books, employment registers and electronic HR document management. This increases transparency of service record and guarantees for employees and enables employers to optimise personnel records and interaction with public authorities.​ At the same time, digital systems record violations in real time, so a merely formal approach to HR documentation becomes impossible: errors can quickly result in fines. Labour inspections strengthen not only punitive but also preventive functions – they provide guidance, recommendations and help settle disputes, changing the model of interaction between business and supervisory authorities.​ Practical steps for business and employeesEmployees should already start carefully reviewing the content of their employment contracts, working‑conditions clauses, working‑time arrangements, opportunities for remote work and leave, and should monitor information about their service record in electronic registers. It is important to understand that the new Code expands the tools for protection of rights – from participation in social dialogue to individual labour disputes – but their effectiveness depends on how well employees are informed.​ Employers should audit their HR documents, update templates of employment contracts and internal regulations in line with the planned changes, and prepare for the transition to electronic record‑keeping. It is advisable to invest in training HR specialists and lawyers and to build dialogue with employees and trade unions so that the new rules are implemented not only formally but as part of a sustainable HR policy that meets European standards of decent work.​ If you have any questions or issues related to the application of the new Labour Code, assessment of risks for employees or business, preparation of employment contracts, internal regulations or HR documentation, you should seek professional legal support – timely advice will help you avoid fines, disputes and financial losses.​ Author – Svitlana Krutorohova, attorney at the Law Firm “Legal Company WINNER”. https://youtu.be/YY3hJJXNUGk?si=90PLHjhFSs0RG6p_https://www.youtube.com/watch?v=XHOmBV4js_E

The government has reached the final stage of the labour reform: the draft of the new Labour Code has been prepared by the Ministry of Economy and approved by the Cabinet of Ministers for submission to the Verkhovna Rada. The document is intended to replace the outdated Labour Code of 1971 and become the foundation of a modern labour market oriented towards European integration, digital employment, better protection of employees and a balance of business interests.​ Why is labour legislation being updatedThe new Code is designed to comprehensively reset labour rules and finally abandon the Soviet model that no longer corresponds to the realities of the war‑time and post‑war economy. At the same time, Ukraine is implementing EU directives on working conditions, working time, reconciliation of work and family responsibilities, and occupational safety as part of its European integration commitments.​For businesses, the reform reduces legal uncertainty by replacing numerous “patches” to the current Labour Code with a single code containing transparent procedures and predictable consequences. For employees, it is an opportunity to obtain clearer guarantees aligned with the practice of flexible, remote and digital employment.​ Key novelties of the Labour Code draftOne of the key blocks is the digitalisation of labour relations: electronic documents and employment contracts are equated with paper ones, which reduces bureaucracy, facilitates remote interaction and makes HR procedures more transparent.​The draft also systematises and expands the types of employment contracts, providing for several types that can be flexibly combined (including remote and project‑based work, flexible working time) in order to legalise widespread but still “grey” formats of work and reduce risks for both employers and employees.​ Balance of interests between employee and employerThe draft codifies modern guarantees for employees – from the right to fair remuneration and safe working conditions to protection against discrimination and transparent procedures for resolving employment disputes. An important element is the strengthening of social dialogue: the document was developed with the participation of trade unions, employers’ organisations, experts and international partners, including the ILO.​For employers, clear indicators of employment relations are introduced to limit the misuse of civil‑law contracts to “disguise” actual employment and at the same time provide comprehensible criteria for inspections by the labour authority. Due to the detailed procedures for hiring, transfer, dismissal, rest time and collective bargaining mechanisms, the number of disputes and the costs of resolving them are expected to decrease.​ Minimum wage, flexibility and EU standardsThe draft introduces a transparent mechanism for determining the minimum wage – on a monthly and hourly basis using a formula aligned with international standards, which should reduce political arbitrariness and link the “minimum wage” to productivity and social minima.​It also integrates European approaches to flexible employment: non‑standard forms of work, remote and part‑time employment, shift work and the reconciliation of work and family responsibilities are regulated, which is particularly important for the post‑war labour market, the return of veterans and the integration of internally displaced persons.​ What this means for businesses and employees nowThe actual launch of the new Code will depend on the speed of parliamentary consideration, but the political signal is already clear: the old Labour Code will be replaced by a comprehensive codification. Businesses should already analyse their HR documents and models of interaction with staff and prepare for the transition to electronic formats, flexible contracts and clear criteria for employment relations.​Employees should carefully monitor the wording of guarantees in the final text, as the new Code will affect the working regime, opportunities to reconcile work and family life, protection from discrimination, the dismissal procedure and ways to protect their rights. For both sides, this is a transition to a model in which electronic tools, European standards and detailed procedures become the rule rather than the exception. If you have any questions or issues related to the application of the new Labour Code draft, the conclusion of employment contracts, changes in working conditions, dismissal of employees or the protection of your rights in employment relations, seek professional legal advice to analyse your specific situation and choose the optimal strategy. Author – Svitlana Krutorohova, attorney at the Law Firm “Legal Company WINNER”. https://youtu.be/YY3hJJXNUGk?si=90PLHjhFSs0RG6p_https://www.youtube.com/watch?v=XHOmBV4js_E

Stopping a vehicle without grounds provided by law constitutes unlawful interference with a person’s right to freedom of movement and to respect for private life. Such a stop violates the requirements of Article 35 of the Law of Ukraine “On the National Police” and leads to the inadmissibility of the evidence collected, as well as the possibility of bringing the police officer to legal liability.​​ Legal framework: what Article 35 actually allowsArticle 35 of the Law of Ukraine “On the National Police” provides an exhaustive list of situations in which a police officer may stop a vehicle. These grounds include, in particular: violation of traffic rules, the presence of obvious signs of technical malfunction, information on the involvement of the driver or passengers in a traffic accident, a criminal or administrative offence, the vehicle being wanted, the need to question or involve the driver in providing assistance, a decision of a competent authority to restrict traffic, dangerous securing of cargo, violation of the rules for the use of special signals, as well as specific grounds regarding vehicles registered abroad. Any other reason – for example, “just checking documents”, “preventive inspection”, “operational and preventive measures” without further specification – is not included in this list and is therefore unlawful as it contradicts the principle of legality of police activities.​​ Groundless stop: what exactly is the violationThe law directly links the power to stop a vehicle with the existence of a specific ground provided by law, and not with a general “suspicion” or the police officer’s internal conviction. The requirement to state the reason for the stop is not a formality: the absence of a clearly formulated lawful ground means that the stop itself is unlawful, and subsequent actions (document check, inspection, issuing a decision) amount to unlawful interference with the driver’s rights. In practice, there are widespread “false grounds” such as “document check”, “alcohol check without signs of intoxication”, “check regarding mobilisation” etc. – all of them, in the absence of a specific reference to the grounds of Article 35, constitute an abuse of powers.​ Courts’ position: consequences of an unlawful stopCourts repeatedly emphasise that the lawfulness of any further proceedings depends on the lawfulness of the initial stop. If the police officer fails to prove the existence of grounds provided by Article 35, reports, decisions and other materials are considered inadmissible evidence, and the proceedings are usually closed due to the absence of the elements or the event of an offence. In high‑profile cases, courts have stressed that the officer is obliged not only to state the reason for the stop, but also to corroborate it with proper evidence (video recording, lookout notices, search materials), and, where such evidence is lacking, have found fines unlawful and issued separate rulings concerning violations committed by the police.​ Driver’s rights in case of an unlawful stop1.To demand that the police officer clearly state the legal ground for the stop with reference to Article 35 of the Law “On the National Police”.2.To record communication with the police officer on video without obstructing the performance of lawful orders.3.If a ground not provided by law is cited, to state that it is unlawful and request that the unlawful actions be stopped.4.If unlawful actions continue, to call another patrol unit via 102 to record the violations.​ 5.To subsequently challenge police actions through administrative procedures (complaints to superiors, the State Bureau of Investigation, the Ukrainian Parliament Commissioner for Human Rights) or in court.6.To avoid resisting lawful orders (for example, presenting documents) so as not to create the risk of a separate offence, and instead to build a defence based on recording the violations and challenging them afterwards. Practical tips and the role of a lawyerFor an effective defence, it is advisable to immediately record all circumstances: time, place, patrol car number, the officer’s name, the contents of the stated reason for the stop, and to keep continuous video recording. Subsequently, these materials may become key evidence when challenging the decision or police actions, since it is the police that must prove the lawfulness of the stop and the legitimacy of subsequent procedural actions. Engaging a lawyer makes it possible to correctly qualify the violations, choose the optimal method of protection (cancellation of the decision, compensation for damage, disciplinary or even criminal liability of the police officers) and minimise the risks for the driver associated with incorrect actions taken “on the spot”. If you have any questions or issues related to a vehicle stop without grounds provided by law, challenging police actions or imposed fines, you should seek individual legal advice in order to assess your situation and protect your rights in administrative or judicial proceedings. Author: Yevhenii Murchenko, Head of the Criminal Law and Procedure Practice of the law firm “WINNER”. https://www.youtube.com/watch?v=S9C2nn5VO0I&t=3s

From 1 January 2026, the deadlines for notaries to submit information to the State Tax Service on certified transactions and other actions having tax implications will change. This concerns data on inheritance cases, real estate sale and purchase agreements, disposal of corporate rights, registration of powers of attorney and prenuptial agreements, which are used for tax administration and control over payment of personal income tax and the military levy. Main legislative innovationsUntil 2026, notaries were required to submit information on certified transactions to the tax authorities no later than the next working day after registration in the Unified Register of Notarial Actions, which in practice meant daily reporting and a significant workload. From 1 January 2026, weekly submission of consolidated information will be introduced: by Monday of the following week notaries will submit data on all actions performed from Monday to Sunday, while in cases where a transaction immediately creates tax liabilities, the information will still be submitted on the day it is certified. Purpose of the changesThe purpose of the changes is to streamline the reporting process and reduce the administrative burden on notaries, since daily informing of the tax authorities generated an excessive number of technical operations without a tangible increase in control. The tax service expects that the weekly format will improve data quality, allow time to correct errors and validate files, and create a basis for automatic reconciliation of information with the registers of the Ministry of Justice, which in the long run will reduce the number of information requests to notaries. Technical aspects of the new procedureInformation will continue to be submitted in electronic form via a specialized module of the State Tax Service integrated with the Ministry of Justice’s registers, using an enhanced electronic signature, automatic completion of part of the fields, improved file validity checks and simplified submission of clarifications. During the first quarter of 2026 a transitional period will apply, allowing parallel submission under the old rules, and from the second quarter the new procedure will become mandatory for all notaries. Liability for late submissionFrom 2026, liability for failure to observe the deadlines will be differentiated: First violation: a warning or a fine of up to UAH 600. Repeated violation within a year: a fine ranging from UAH 1,200 to UAH 2,500. Systematic violations (three or more times): a possible referral to the Ministry of Justice regarding disciplinary liability.This approach takes into account the good faith of the notary and the technical circumstances of the violation and demonstrates a shift from a repressive to a more partnership‑oriented model of tax policy. Practical impact on notarial activitiesThe new rules will be both a relief and a challenge for notaries: less frequent reporting will simplify work organization, but weekly consolidation of large volumes of documents will require a clear internal system of record‑keeping. Methodological guidance is expected to be developed by notarial chambers, and automatic control of data consistency between the systems of the State Tax Service and the Ministry of Justice should help quickly detect technical inaccuracies in documents. Potential risks and mitigationThe main risk is possible technical failures at the initial stage of implementing the new format, so the tax authorities are already preparing test environments to verify the readiness of software solutions. Large notarial firms will need to adapt their internal processes through intermediate stages of data control and ensure reliable storage of electronic reporting archives for at least five years, supported by updated cybersecurity and backup policies. Looking aheadExperts suggest that by 2027 the tax authorities may launch an integrated interaction platform with notaries, where information will be transmitted automatically from the Unified Register of Notarial Actions, making manual report generation redundant. The current changes are an intermediate step towards full digitalization of data exchange and are intended to simplify interaction between the state and notaries and to increase the transparency of tax flows arising from certified transactions. If you have any questions or issues related to the application of the new procedure for submission of information by notaries to the tax authorities, you should seek advice from specialists in tax and notarial law. Author: Ihor Yasko, Managing Partner at Attorneys at Law “WINNER”, PhD in Law. https://youtu.be/4nzvofPywF0?si=GznwsTBZiQwi9pMJ

In 2025, the State Tax Service of Ukraine enhanced control automation by expanding analytical selection of taxpayers for on-site inspections, and from 2026 the SOD RRO system will play a key role in this process as the main tool of risk‑based tax control and business tax risk formation. What SOD RRO is and what information it accumulatesSOD RRO is a centralized system that collects and analyzes data from RRO and PRRO in real time (sales volumes, time and frequency of operations, average receipt, product range, taxation regime, place of activity, etc.), having evolved from a technical repository of fiscal receipts into an analytical hub that enables automatic selection of taxpayers for on-site inspections based on calculated risk indicators. Principles of risk profile formation Financial and operational anomalies: significantly lower volumes of RRO operations compared to peers or a sharp unjustified drop in revenue. Behavioral indicators: atypical operating mode of RRO, sharp fluctuations in the number of receipts, frequent re-registrations of devices, unusual dynamics of the average receipt. “Connected group” factor: detection of related individual entrepreneurs/companies by addresses, PRRO accounts, IP addresses or personnel and formation of a “risk cluster”. Comparison of official and actual flows: cross-check of RRO data with VAT, single tax and social contribution reporting; material discrepancies classify the entity as high‑risk. The taxpayer’s profile is additionally refined through integration of SOD RRO with other analytical systems of the State Tax Service, which makes it possible to assess the statistical probability of violations. New procedure for initiating on-site inspectionsThe key practical change is the almost complete elimination of the “human factor” in initiating on-site inspections: whereas previously the grounds were citizens’ complaints or law‑enforcement materials, now inspections are launched by the system, which, based on automatic risk scoring, generates an electronic submission, while an official only approves it and issues an order without changing the formal grounds set out in Articles 80–81 of the Tax Code of Ukraine. Implications for business The risk of “automatic” inspections increases, and businesses do not always understand which specific anomaly triggered inclusion in the risk list. Requirements for accounting discipline are tightening: proper PRRO settings, alignment with bookkeeping and correct product categorization are needed. Preventive analytics becomes essential, meaning regular self‑monitoring of RRO indicators and detection of discrepancies between cash register and tax data. The issue of evidentiary standards becomes more acute, since the opacity of analytical criteria may lead to litigation regarding the legality of inspection orders. Outlook for further developmentSOD RRO is gradually becoming the core of an integrated digital tax control model, and in future it is planned to be strengthened by connecting acquiring data, the fuel expenses register and excisable goods control systems, which will significantly expand tax monitoring and make manipulation of accounting in trade or services almost impossible without a technical trace, while at the same time a high risk of algorithm “false positives” will remain, so proving good‑faith conduct through legal instruments will continue to be a key condition for business security. Recommendations for business entitiesCheck PRRO settings and the accuracy of registration data in SOD RRO.Avoid systematic errors in fiscal receipts (incorrect UKT ZED codes, VAT rates, price mismatches).Conduct internal audits of the regularity and completeness of transaction fiscalization.Keep a cash‑register event log and record all PRRO technical failures, deferred receipts and service interruptions.Document internal decisions on changes in RRO operating mode, as this evidence may become an argument during an inspection.Introduce personal liability of cashiers and managers for the accuracy of data in receipts. ConclusionThe SOD RRO system is fundamentally transforming tax control in Ukraine by making taxpayer selection for inspections more structured, rapid and technically justified, which in the long term will improve tax discipline while requiring businesses to carefully manage their digital footprints, since shifting control into the realm of algorithms and data increases efficiency but also reinforces the need for legal protection against possible analytical errors. If you have any questions or issues related to applying the SOD RRO system, risks of on-site inspections or preparation for tax control, please contact our tax law experts for advice. Author – Yuliia Popadyn, attorney in the tax and housing law practice of the law firm “Legal Company WINNER”. https://youtu.be/m5aS_Sby2c8?si=0IFTxXFxoYCPhgfk

From 26 February 2026, amendments to the procedure for sending tax notices-decisions (TNDs) will enter into force under Order of the Ministry of Finance No. 1204. These amendments take into account the digitalisation of tax procedures, expand electronic document flow and clarify the rules for determining the moment a TND is deemed served on the taxpayer.​ The State Tax Service has developed these changes to reduce the number of disputes regarding proper notification of taxpayers and to harmonise the procedure with legislation on electronic documents and the Tax Code. In practice, the updated procedure effectively introduces a “single window” of electronic communication between the tax authorities and taxpayers.​ Main innovations of the procedure The electronic form becomes the primary method of sending TNDs: via the electronic taxpayer’s cabinet, while paper notices will be used only where there is no access to, or consent to, electronic interaction.​ The moment of service of a TND is linked to its appearance in the “Incoming documents” section of the electronic cabinet, regardless of whether it is actually read, which obliges taxpayers to monitor their cabinet regularly.​ For large taxpayers, a separate electronic channel with enhanced signatures and centralised document flow is introduced, with a gradual phase-out of postal dispatches in 2026.​ Each TND will receive a unique digital identifier synchronised with the STS databases and the electronic cabinet, which will facilitate work with amending returns and appeals.​ TNDs may be appealed directly via the electronic cabinet, with the possibility to attach electronic evidence and automatically generate confirmation of the complaint filing date.​ Practical consequences for taxpayersFor businesses, the changes mean not only streamlined document flow but also new risks: the moment of receipt of a TND will no longer depend on the fact of familiarisation, but only on its delivery to the electronic cabinet, so arguments about delays or absence of postal notices will no longer be effective. Missing the 10‑day administrative appeal period for TNDs sent via the electronic cabinet will have the same consequences as for paper documents, so companies should introduce daily monitoring of the electronic cabinet, especially where there is a high volume of transactions.​ For individual entrepreneurs the situation is simpler: tax decisions can also be monitored via the “Diia” mobile application, which is synchronised with the taxpayer’s electronic cabinet.​ Impact on court practiceThe new procedure is likely to reduce the number of disputes about proper service of TNDs, which previously made up a significant share of administrative tax cases. At the same time, courts will face new tasks: assessing technical failures of the electronic cabinet, the taxpayer’s actual access to it and compliance with the document placement regulations, which will lead to more active use of digital evidence such as technical logs, reports, electronic certificates and delivery notifications.​ Digitalisation as a basis for administrative reformThe updated procedure for sending TNDs is part of a broader digital tax interaction strategy up to 2030, which envisages a gradual abandonment of paper correspondence between taxpayers and tax authorities. The new procedure logically continues the development of the Single Electronic Taxpayer’s Cabinet, intended to consolidate all notices, registers and reporting in a single digital environment, reducing state postal costs, speeding up administration and simultaneously increasing transparency and procedural discipline requirements for taxpayers.​ Potential implementation challengesDespite optimistic expectations, a number of potential difficulties should be considered: not all taxpayers have stable access to electronic services (especially under martial law or in areas with unstable internet). There may be problems with user authentication via qualified e‑signatures and the trust services system during peak loads. Additional work is required on amending procedural rules on service and appeal periods, as well as adapting taxpayers’ internal IT systems for automatic tracking of TNDs, while the effectiveness of the new procedure will depend on the technical readiness of the tax authorities and their response speed to technical failures.​ ConclusionsThe updated procedure for sending tax notices-decisions is an important stage in the digitalisation of tax administration, aimed at reducing bureaucracy, increasing procedural transparency and speeding up communication between the state and business. At the same time, the new rules increase the requirements for taxpayers’ vigilance: the electronic cabinet is turning from an auxiliary service into a fully legally significant environment that is integral to tax administration processes.​ If you have any questions or issues related to interpreting the new rules for sending TNDs, the time limits for their appeal or the procedure for electronic interaction with the STS, you should seek advice from a tax consultant or a lawyer experienced in handling tax disputes. The author is Maksym Bahniuk, Head of the Tax and Customs Law Practice at the law firm “WINNER”. https://youtu.be/BL8jBRRsSTI?si=rtO6fKm3n1AdUKDF

Normative basis of the responsibility of the Military Medical Commission (MMC)The procedure for the work of the MMC is regulated by the Regulation on Military Medical Examinations in the Armed Forces of Ukraine (Order of the Ministry of Defence of Ukraine No. 402), which requires an actual, comprehensive and objective medical examination of every person. The MMC is obliged not only to formally collect doctors’ signatures, but also to establish a specific diagnosis, assess the functional condition and make a well‑reasoned conclusion on fitness based on medical records and examination results.​The Code of Administrative Procedure of Ukraine imposes on the public authority the duty to prove the lawfulness of its actions and decisions, and on the court – to verify whether the MMC acted within the granted powers and in the manner prescribed by law. Pursuant to Article 19 of the Constitution, state bodies and officials must act only on the basis of, within the scope of powers and in the manner determined by law, which directly extends to MMCs operating at Territorial Recruitment and Social Support Centres.​ Judicial approach to formal examinationsIn an administrative court decision that formed the basis for the conclusion that “a formal examination and ignoring complaints is a ground for annulment of an MMC decision”, the court stated that there had been no real assessment of the claimant’s state of health. The MMC certificate did not reflect the examination results in the form of a diagnosis, contained no data on the necessary tests, and the medical complaints and submitted documents were effectively ignored, which the court regarded as an incomplete and improper medical examination.Similar conclusions appear in other cases where courts find MMC decisions unlawful if the examination was not conducted by all necessary specialists, chronic diseases were not taken into account, medical documents were not added to the file, or additional tests were refused. In some cases, courts annul not only the decisions of local MMCs but also those of the Central MMC if bias, a purely formal assessment and disregard of evidence concerning the person’s actual state of health are established. Ignoring complaints as a procedural violationA person’s complaints about pain, limited mobility and neurological, cardiological or other symptoms are not merely subjective “complaints for the sake of deferment from mobilisation” but a legally significant element of the examination procedure. Courts explicitly state that the MMC’s failure to respond to such complaints, refusal to refer for additional tests and failure to consider the diagnostic results provided constitutes a breach of the established procedure for conducting a medical examination.Ignoring requests for a repeat examination or for review of an MMC decision is also qualified as unlawful inaction, which further demonstrates a formalistic approach and becomes an independent ground for judicial intervention. In such circumstances, courts apply Article 2 of the Code of Administrative Procedure of Ukraine, examining whether the MMC’s decisions met the criteria of lawfulness, reasonableness, proportionality and proper reasoning.​ Consequences: annulment of MMC decision and repeat examinationThe typical “set” of consequences applied by administrative courts in disputes with MMCs consists of two elements: recognition of the MMC’s decision (or actions) as unlawful and its annulment; and an order to carry out a repeat, comprehensive medical examination taking into account all complaints and medical records. In a number of cases, courts directly indicate the need for examination by all relevant specialists, for additional tests to be ordered, and for proper recording of results in medical documentation, and sometimes also the need for the participation of a higher‑level MMC.Importantly, courts do not replace the MMC’s medical conclusion with their own assessment of the diagnosis but only remove the unlawful decision and oblige the commission to act in accordance with the law and medical standards. For persons liable for military service this means that a purely formal examination without real consideration of complaints and health status can be effectively challenged, and a repeat examination becomes an opportunity to obtain an objective conclusion.​ Practical conclusions for rights protectionCourt practice confirms that a formal medical examination at a Territorial Recruitment and Social Support Centre and the ignoring of complaints are not minor procedural flaws but material violations that affect the fitness conclusion and therefore lead to annulment of the MMC decision. The key to successful judicial protection is an adequate evidentiary basis: complete medical documentation, proper recording of actual complaints, applications to the MMC and the Territorial Centre, copies of requests for a repeat examination, as well as references to Regulation No. 402 and administrative court practice.​If you have questions or problems related to undergoing an MMC examination, challenging a commission decision, preparing medical evidence or litigating against a Territorial Recruitment and Social Support Centre, it is advisable to consult a lawyer who specialises in military law and has practical experience in such cases. Author – Svitlana Krutorohova, attorney at the Law Firm “Legal Company WINNER”. https://youtu.be/BL8jBRRsSTI?si=clE4VkaIFbUYTwyt

Hetmantsev insists that body cameras should become a mandatory element during all inspections and contacts between tax officials and businesses, turning from a technical innovation into an instrument of trust and transparency in relations between the state and business.Context and background of the initiativeUkrainian business has traditionally been sceptical about visits from tax inspectors, and the post‑war economic recovery, the pause in the reform of the State Tax Service, and the increase in complaints about abuses have only strengthened the demand for transparency of state institutions. The government and the Verkhovna Rada in 2024 intensified the digitalization of fiscal processes – electronic inspection reports, automated risk‑based selection of taxpayers, integration of video recording – which is shaping a new system of “tax security”, where body cameras are logically intended to reduce subjectivism and abuses. Hetmantsev emphasizes that similar practice is already used by the police, customs, the State Bureau of Investigation and NABU, protecting both citizens and officials who obtain video evidence in cases of conflicts or accusations of abuse of power. Regulatory and technical componentThe initiative provides for amendments to the Tax Code that will directly oblige officials of the State Tax Service to record inspections on video and to store the recordings for a specified period, while lawyers insist on at least a one‑year term for potential court disputes. It is planned to create a centralized database of video recordings with limited access for authorized units of the State Tax Service, the State Audit Service, courts and law‑enforcement bodies, as well as to equip inspectors with the necessary devices and to approve internal guidelines on ethics and data confidentiality. Arguments “for” Transparency of interaction. Video recording minimizes the risks of pressure or corrupt actions, since every fact of communication is recorded on camera. Protection of business rights. Entrepreneurs receive an additional evidentiary mechanism in the event of a dispute, including when challenging the results of an inspection. Evidentiary base for internal investigations. If complaints are filed about the behaviour of specific officials, body cameras ensure the objectivity of the assessment. Psychological effect. The very existence of a recording disciplines both parties and reduces aggressive or emotional reactions. Arguments “against” and criticismOpponents stress that body cameras will not become a “magic pill” against abuses without changes in staffing culture, integrity standards and real accountability of officials. Doubts are also raised by the costs of equipping several thousand inspectors, creating the infrastructure for storing video and protecting data under wartime budget constraints, as well as the risks to the commercial and personal information of businesses, which require clear rules for processing, anonymizing and using recordings in court. Comparison with international experienceIn a number of countries, including the United Kingdom, Canada and the Netherlands, body cameras have long been used by police officers, customs officers and tax inspectors. In the Netherlands, video recording of field inspections has been a standard since 2019, which has helped reduce the number of complaints and speed up their consideration; Ukraine declares its intention to follow such models, but success will require not only the technical component, but also integration of video recording with a risk‑based system of taxpayer selection, so that inspections are carried out according to transparent criteria rather than at the discretion of individual tax officials. Impact on tax cultureIf the initiative is fully implemented, it may become a catalyst for forming a new culture of tax administration. When business understands that its rights are protected and an inspector cannot act “off camera”, the level of trust in the state naturally increases. However, it is important that implementation does not turn into a formality: if body cameras are switched on only partially or recordings disappear, trust will be lost completely. Here, internal audit and external control by parliamentary and civil society structures must play a key role. Legal perspectiveLawyers emphasize that a tax inspector, as an official of a state body, must act as openly as possible, and video recordings can be admissible evidence in cases of abuse of power or violations of inspection procedures. At the same time, a unified approach to the authenticity of recordings will be crucial for court practice – through technical marking (time‑stamps, GPS coordinates) or a single register of recordings – and under such conditions Hetmantsev’s initiative may transform tax control from a punitive mechanism into a service function of the state, where the inspector and the entrepreneur are in more equal conditions in terms of information protection. Political dimensionThe political aspect of the initiative is also significant: in the context of the need to restore trust in institutions and reduce the shadow economy, body cameras can become a symbol of a “new integrity of the authorities”. For Hetmantsev, this is not only a tool of control but also a manifestation of political responsibility: if the state demands transparency from business, it must be the first to demonstrate transparency in its own actions. Final paragraphIf you have any questions or problems related to the activities of tax authorities, preparation for tax inspections, video recording of inspectors’ actions or challenging the results of an inspection, please contact our specialists for an individual consultation. Author: Ihor Yasko, Managing Partner at “WINNER” Law Firm, PhD in Law. https://youtu.be/WU7J13eUo6U?si=fnqHoRgcz0Sm9AWy