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VAT for FOPs 2027: What is known?

FOPs with income from 1 million hryvnias will pay 20% VAT from 1 January 2027: position of the Ministry of Finance and consequences of the changes.​At the end of 2025, the Ministry of Finance of Ukraine published a draft law that caused significant resonance among small‑business representatives. According to the document, from 1 January 2027 individual entrepreneurs (FOPs) whose annual income exceeds 1 million hryvnias will be obliged to register as value added tax payers and pay 20% VAT. This step will become one of the most visible stages of the “restart” of the simplified taxation system, aimed at its gradual approximation to the general model of tax administration.​ Background to the changes. The Ministry of Finance justifies the initiative by the need to reduce fiscal losses and ensure equal competitive conditions among business entities. According to the ministry, the current simplified system model creates a “tax gap” between FOPs and legal entities, which complicates control over shadow schemes and leads to under‑reporting of real income volumes. Due to low tax burden and the absence of VAT accounting, part of FOPs in fact operate as medium‑sized businesses, receiving significant profit without appropriate taxation. The Ministry notes that such practice does not comply with the principles of fairness and equal access to the market. The draft law explicitly states that the introduction of VAT for FOPs with income above 1 million UAH will increase transparency of settlements, discipline business and at the same time raise budget revenues.​ How the 1‑million‑hryvnia threshold works. Under the proposed rules, the 1‑million‑hryvnia indicator will be determined based on the results of the calendar year. If a FOP’s income exceeds this threshold, they automatically fall into the category obliged to register as a VAT payer no later than 1 January of the following year. In addition, a separate reporting and administration procedure will be established for such entrepreneurs, bringing them closer to the standards applied to ordinary taxpayers on the general system. According to the authors of the draft law, the 1‑million‑UAH threshold is a “fair compromise” between protecting micro‑business and strengthening tax discipline. Thus, FOPs with a small turnover will remain in a preferential regime without VAT, while entrepreneurs whose income indicates de facto participation in mid‑level trade will be included in the unified tax accounting contour.​ New rules for simplified taxpayers. The Ministry’s draft also proposes to update the very philosophy of the simplified system. It envisages a revision of limits for all groups of single‑tax payers and a gradual abolition of the simplified regime for certain types of activities that display signs of “disguised” medium‑sized business — in particular wholesale trade, IT outsourcing, advertising services and the like. In addition to mandatory VAT, for FOPs whose income exceeds 1 million UAH a phased introduction of electronic transaction accounting, mandatory use of cash‑register equipment and submission of quarterly reporting is planned. These steps are a logical continuation of the tax system’s digitalisation, which has been actively progressing since 2022.​ Potential benefits for the state. The Ministry of Finance estimates possible additional revenues from the reform at 25–30 billion UAH annually. A reduction in the volume of “grey” operations is also expected, when legal entities artificially split their activities into several FOPs to avoid VAT or corporate income tax. The introduction of VAT for a specific group of entrepreneurs should also create an incentive to legalise supply chains, since legal entities will find it more beneficial to work with VAT‑paying counterparties that can provide tax credits. The Ministry predicts that this will increase overall business‑environment transparency and facilitate control over cash flows.​ Risks for small business. The business community has reacted ambiguously to the initiative. Expert associations warn that the introduction of 20% VAT may become an excessive burden for small traders and service companies that work with final consumers and do not have access to tax credits. For them, the additional fiscal burden may in practice mean higher prices or reduced margins. There are also concerns that some businesses will simply “go into the shadows” to avoid the new tax. Given the insufficient level of trust in tax authorities and the complexity of VAT accounting, such risks cannot be ruled out. Economists emphasize that without simplification of administrative procedures and effective electronic tools, the reform may have the opposite effect — increasing the burden without a substantial rise in revenues.​ Position of business associations and public consultations. At the time of publication, public discussions of the document are ongoing. The Federation of Small and Medium‑Sized Business of Ukraine has already appealed to the Ministry of Finance with a proposal to raise the threshold for mandatory VAT registration to 2 million UAH or to introduce a gradual transition — for example, 10% in the first year and only from 2029 to increase the rate to 20%. Some experts also propose introducing an adaptation period, giving entrepreneurs 6–12 months to organise their accounting and set up electronic reporting. Others stress the need to simultaneously reduce the single‑tax rate for this category or to introduce a mechanism for partial offset of VAT paid.​ European context. Introducing VAT for entrepreneurs above a certain income level corresponds to common European practice. In most EU countries, similar thresholds range from 35 to 100 thousand euros. Thus, the Ukrainian threshold of 1 million UAH (about 25–26 thousand euros) is even below the average. On the other hand, the EU has advanced mechanisms of automatic VAT crediting, compensation and fast refunds, which the Ukrainian system still lacks. At the same time, experts note that harmonising tax rules with European standards is a necessary condition for Ukraine’s further integration into the EU internal market. In this context, the introduction of “threshold” VAT for FOPs is perceived not as an isolated fiscal measure but as a stage of comprehensive regulatory convergence.​ What entrepreneurs should expect. The next two years will serve as a preparatory period. In 2026, the law itself and a series of by‑laws detailing the new rules of accounting, reporting and

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Counterparty errors that lead to fines: how to protect your business from tax risks

In the modern business environment, choosing a reliable counterparty has long ceased to be a mere formality. Even a single mistake by a partner may become grounds for fines, additional tax assessments, or even blocking of tax invoices. It is not uncommon for companies that diligently perform their obligations to face claims from supervisory authorities precisely because of the negligence or unlawful actions of their counterparties. Errors in registration data: “small details” that cost a lotThe most common issue is incorrectly completed or untimely updated registration data of the counterparty. A change of director or registered address may seem like a technicality. However, in practice this can lead to legal conflicts: a contract is signed by a person who has already lost their authority, or document flow is directed to an outdated address.Tax authorities often use such “formal” inconsistencies as an argument to treat a transaction as non-genuine. As a result, the purchasing company risks losing the right to deduct expenses or claim VAT input credit. Issues with tax invoicesLate or incorrect registration of tax invoices is one of the key reasons for penalties. If the supplier fails to register the invoice on time, the purchaser’s VAT credit is at risk. In some cases, the business may lose it completely if the deadlines are irreversibly missed.It is also important to mention situations where the counterparty turns out to be a fictitious VAT payer. In such cases, the tax authority often treats the transaction as “non-real”, even if all documents are properly issued and the goods or services have in fact been received. Mismatch between actual operations and documentsAnother typical mistake is the discrepancy between the actual delivery conditions and those specified in contracts or primary documents. For example, the goods are delivered to a different address, or delivery notes are signed by unauthorised persons.In such situations, the tax authority may question the very fact of the business transaction. Court practice shows that formally correct but factually inconsistent documents are a weak argument in defending a company during an audit. Problems with the counterparty’s business reputationSupervisory authorities increasingly verify the “business purpose” of transactions and the reality of business activities. If a counterparty has no staff, production resources, assets, or clearly does not carry out economic activity, this raises suspicion of fictitiousness.Even if your company acted in good faith, the lack of “due diligence” when choosing a partner may result in denial of VAT credit or fines. Court practice confirms that responsibility for checking counterparties lies not only with tax authorities, but also with the business entities themselves. Errors in drafting contracts and primary documentsA contract signed without specifying essential terms, or a specification without signatures, are typical reasons why a transaction may be declared invalid or non-real. The tax service actively relies on this argument during audits, since the absence of a signature or stamp (where required by the contract) allows it to question the very fact of performance.Equally risky is when documents are backdated or contain conflicting dates. Such inconsistencies are inevitably revealed during tax monitoring and may trigger penalties. Participation in risky schemes: supply “chains”Businesses often find themselves in a chain of transactions with counterparties that exist only formally to document dubious operations. Even if your company is at the end of such a chain and has no intention of tax evasion, it may still become subject to VAT credit blocking or be classified as a “risky taxpayer”.Only systematic prevention helps in such cases: checking counterparties’ history, analysing typical risk codes in the Unified Register of Tax Invoices, and monitoring court decisions concerning potential partners. Negligence in communication and evidence retentionIn many disputes, the taxpayer cannot promptly confirm the actual performance of a contract. The absence of correspondence, acceptance certificates or even basic proof of goods transportation plays into the hands of the tax authorities.Today, the evidentiary base must be preserved not only on paper but also in electronic form: e‑mail, messengers, internal orders, GPS data of carriers. All of this may become convincing evidence of good faith during an audit. How to minimise risksTo avoid the consequences of others’ mistakes, each company should implement an internal counterparty screening mechanism. It should include:checking registration data via the Unified State Register and the VAT payers’ register;analysing court decisions related to the counterparty;verifying contact persons, and the existence of an office or production facilities;keeping copies of all documents and communications;performing periodic checks even of long-term partners, as the status of any company may change.Thorough counterparty due diligence at the contract stage is not only a legal safeguard but also a matter of financial security. Even a minor error by another company can cost yours tens of thousands of hryvnias in penalties and lengthy litigation. Author – Yuliia Popadyn, attorney in tax and housing law practice at the Attorneys Association “WINNER Law Firm”. If you have any questions or issues related to counterparty due diligence, tax risks, or appealing decisions of supervisory authorities, the experts of WINNER Law Firm are ready to provide professional assistance and protect your interests. https://youtu.be/rEd6me-Ume4?si=XEZ1CiGBh1NK_TrM

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Strengthening financial monitoring and the account register: new requirements for businesses

In 2025, Ukraine continues to reform its financial monitoring system by expanding mechanisms for controlling financial transactions and introducing new tools to increase economic transparency.One of the most important recent initiatives has been the launch and active use of the Accounts Register, an electronic database containing information on all bank accounts held by individuals and legal entities. The role of financial monitoring for the economyFinancial monitoring is a set of measures aimed at detecting and preventing the laundering of proceeds of crime and the financing of terrorism.The main authority responsible for this activity in Ukraine is the State Financial Monitoring Service.In recent years, the scope of financial monitoring has significantly expanded: it now covers banks, non‑bank financial institutions, payment systems, leasing companies, stock exchanges, real estate agencies, notaries and other business entities. The primary goal of financial monitoring is to ensure transparency of financial flows, strengthen confidence in the Ukrainian financial system and achieve compliance with international standards, in particular the recommendations of the Financial Action Task Force (FATF).Compliance with these standards is a key step for attracting foreign investment and integrating Ukraine into the global economy. Accounts Register: essence and purposeThe Accounts Register is an electronic database containing information on all bank accounts opened in Ukraine.It includes data on account holders, account details, dates of opening and closing, as well as information about the issuing banks.The Register has been created in order to: provide law enforcement bodies, courts and other authorised entities with prompt access to information on financial accounts; increase the effectiveness of criminal investigations, in particular those related to money laundering, tax evasion and fraud; monitor suspicious transactions and detect schemes aimed at hiding assets or evading financial obligations. State authorities, courts, the State Financial Monitoring Service, tax authorities, law‑enforcement agencies and certain obliged entities performing financial monitoring functions have access to the Accounts Register.At the same time, access to the data is restricted and governed by personal data protection legislation. New requirements and obligations for businessThe introduction of the Accounts Register and the tightening of financial monitoring requirements have a significant impact on business.Entrepreneurs and financial institutions are forced to review their internal procedures, implement new control mechanisms for financial transactions and improve the level of documentation and reporting. The main new obligations for businesses include: mandatory provision of comprehensive information on account holders, including beneficial owners; continuous monitoring of transactions for signs of suspicious activity; prompt responses to requests from the State Financial Monitoring Service and other supervisory authorities; implementation of internal control systems capable of detecting and blocking suspicious operations; strict compliance with document‑retention and personal‑data protection requirements. For businesses, this means increased administrative burdens, the need to invest in IT infrastructure and enhanced staff training.However, these measures help build trust in Ukrainian companies among foreign partners and clients. Challenges for entrepreneursDespite the positive effects, the new financial monitoring mechanisms pose several challenges for business: Higher risks of account blocking. Banks are becoming more cautious, and any suspicious transaction may result in temporary blocking of an account, which is especially problematic for companies working with large volumes or complex ownership structures. Lack of clear guidance. Detailed methodological recommendations on how to identify suspicious transactions are not always available, which leads to subjective interpretations by banks. Personal data protection. Use of the Accounts Register raises concerns about the security of confidential information and the risk of unauthorised access or data leaks. Additional costs. Implementing financial monitoring systems, training staff, conducting audits and preparing reports require extra financial and time resources. International experience and outlookIn many European countries, the United States and other developed jurisdictions, account registers and financial monitoring systems have long been integral parts of the financial infrastructure.These mechanisms make it possible to effectively combat money laundering, terrorist financing and other financial crimes.For example, Germany, France and Italy operate centralised databases of bank accounts that law‑enforcement bodies can access under certain conditions. In Ukraine, the introduction of the Accounts Register and stricter financial monitoring is a step towards integration with the international financial system.For this initiative to succeed, it is necessary to: ensure transparent and clear rules; guarantee protection of personal data and prevent abuses; provide businesses with clear methodological guidance and support; continuously update legislation in line with international standards and the real needs of the Ukrainian economy. Impact on the tax system and tackling evasionThe Accounts Register enables tax authorities to quickly obtain information on cash flows, uncover income‑concealment schemes and track suspicious transactions.This creates additional risks for those attempting to evade their tax obligations. At the same time, honest entrepreneurs benefit from a more level playing field, as tax evasion becomes harder to hide.Growing confidence in the tax system contributes to higher tax revenues and greater stability of the state budget. Future developmentIn the future, the functions of the Accounts Register are expected to expand further, including integration with other state registers (such as the beneficial owners register and the register of legal entities) and the use of modern artificial‑intelligence technologies to analyse financial flows.International cooperation in the field of financial monitoring and information exchange between Ukraine and other countries is also expected to intensify, helping to combat cross‑border financial crime more effectively. ConclusionsThe introduction of the Accounts Register and the strengthening of financial monitoring constitute an important step in combating money laundering, terrorist financing and other financial offences.For businesses, this means greater transparency but also higher administrative costs and risks. Author: Ihor Yasko, Managing Partner of WINNER Law Firm, PhD in Law. If you have any questions or face issues related to financial monitoring, the Accounts Register, account blocking or other aspects of fiscal control, you can contact the experts at WINNER Law Firm.They will help you analyse the situation, prepare the necessary documents and protect your interests in dealings with banks and supervisory authorities. https://youtu.be/rEd6me-Ume4?si=XEZ1CiGBh1NK_TrM

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Unblocking tax invoices with different dates: practical aspects and court positions

The practice of blocking tax invoices remains one of the most painful issues for VAT payers. Despite the reform of the risk monitoring procedure and the introduction of new criteria, the State Tax Service (STS) continues to suspend the registration of a significant share of documents, which results in forced disputes, delays, and financial losses for businesses. The situation becomes particularly complicated when tax invoices relate to transactions with different dates but share the same business activity indicators.​ Essence of the problemThe suspension of tax invoice registration most often occurs automatically, as the monitoring system identifies risky transactions or taxpayers. However, a nuance arises when similar invoices are issued on different dates, for example, in parts for the supply of goods or services, and only some of them are blocked.Such situations in fact place the taxpayer in an unequal position: under identical circumstances, they have a different tax result solely because of the invoice issue date. Accordingly, the question arises whether the tax authority may lawfully block invoices with different dates if the economic substance of the transactions and the documents confirm them.​ Reasons for blockingIn practice, several key reasons can be distinguished as to why the system suspends the registration of invoices with different dates:Shift of the supply period. The tax authority believes that the date of the invoice does not correspond to the actual date of occurrence of tax liabilities or the actual supply.Discrepancies in nomenclature or amount. If invoices are drawn up with minor differences in product codes or value, the system perceives this as a sign of risk.Inconsistency of primary documents. When part of the primary documentation covers another calendar period (for example, performance certificates are issued later), the risk filter is automatically triggered.Different tax periods of the counterparty. If the counterparty records the transaction in another reporting period, the STS may consider that the reality of the transaction requires verification.​ Thus, the “different dates” issue is often related not to a breach of legislation but to the technical peculiarities of monitoring. Position of taxpayers and the STSTaxpayers consistently emphasize that the law does not establish restrictions on issuing tax invoices with different dates for the same counterparties or under the same contracts, provided that the actual supply is confirmed by primary documents.At the same time, the STS often treats different dates as a signal of a possible “schematic” transaction, especially where the taxpayer does not have significant turnover or has an excessive tax credit in a particular period.It should be noted that the Procedure for suspension of registration No. 1165 (as amended for 2024–2025) does not define the date of the invoice as an independent risk factor. Therefore, the tax authority must justify its decision for each invoice separately and cannot rely solely on time discrepancies between documents.​ Case lawCase law is becoming increasingly consistent in favour of taxpayers. Administrative courts stress that where a business transaction is confirmed by primary documents and the fact of supply is not disputed, refusal to unblock invoices solely due to different dates is unlawful.For example, in several decisions of the Supreme Court, it is emphasised that risk indicators must be clearly recorded and that the tax authority is obliged to prove specific circumstances indicating the unreality of the transaction. The mere fact of the existence of tax invoices with different dates (even with a difference of several days) cannot be regarded as a sign of fictitiousness.Moreover, the courts have repeatedly indicated that systematic monitoring cannot substitute for a tax audit. If the STS has doubts as to the legality of tax assessments, it is entitled to carry out an audit, but not to block the registration of invoices without sufficient grounds.​ Practical advice on unblockingPrepare a full package of documents. The explanation should be accompanied not only by the contract and invoices but also by acts of acceptance, consignment notes, invoices, bank statements, quality certificates and any other documents evidencing the reality of the supply.Provide a logical explanation of the dates. It is important to explain why the invoices have different dates (split deliveries, technical specifics, completion of works in several stages, etc.).Pay attention to consistency of volumes. If the supply volumes in different invoices correspond to the contract or acts, this should be highlighted in the explanation.Substantiate the allocation of supply. In case of partial delivery or performance of works, explain the sequence and provide confirmation from the counterparty.Monitor the taxpayer’s risk status. If the company is included in the list of risky taxpayers, it is advisable first to submit documents to be removed from this list and only then insist on unblocking the invoices.Appeal the STS decisions. If the commission refuses registration without proper justification, it is advisable to file an administrative lawsuit. Judicial unblocking remains the most effective tool for protecting taxpayers’ rights.​ ConclusionUnblocking tax invoices “with different dates” requires not only a solid evidentiary base but also clear reasoning for the logic behind document issuance. The tax authority should assess not formal indicators (dates, sequence, supply period) but the actual circumstances of the taxpayer’s business activities.For businesses, it is important to document the reality of transactions, avoid technical errors and prepare explanations for the commission in advance. Prompt response to blocking, proper preparation of complaints and, where necessary, recourse to the courts are key to restoring legitimate tax credit and avoiding financial losses.Author: Ihor Yasko, Managing Partner of WINNER Law Firm, PhD in Law. If you have any questions or issues related to the unblocking of tax invoices, the preparation of explanations or the appeal of STS decisions, the WINNER Law Firm team is ready to assist with document preparation and representation of your interests. https://youtu.be/rEd6me-Ume4?si=XEZ1CiGBh1NK_TrM

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How Foreigners Lose Residence Permits in Ukraine: 7 Legal Traps No One Explains

Many foreigners believe that once they obtain a residence permit, the main risks are behind them. In practice, however, most problems begin after the permit is issued.​ Ukrainian migration authorities actively inspect residence permits, exchange information with tax and law‑enforcement bodies, and cancel documents not because of crimes, but because of legal mistakes. Below are the 7 most common legal traps that lead to cancellation of a residence permit.​ Working without an official work permitA residence permit does not automatically give the right to work. Foreigners often: work under civil law contracts; manage companies without a work permit; believe that “entrepreneurial activity” is not employment.Result: cancellation of the residence permit and a possible entry ban. Formal employment without real activityMigration authorities increasingly verify: the actual activity of the company; payment of salaries; tax reporting.“Paper employment” without real work is treated as an abuse of immigration grounds. Missing residence‑permit extension deadlinesEven a short delay may lead to: automatic cancellation of the permit; forced departure from Ukraine; problems with re‑entry.Many foreigners rely on employers or agents and lose control over deadlines. Inconsistencies between migration and tax dataThe tax authorities and the migration service exchange information. Typical “risk signals” include: declared employment without payment of taxes; doing business without tax registration; discrepancies in income.Tax mistakes often become a ground for migration problems. Incorrect grounds for obtaining a permitCommon mistakes: using a business visa instead of a residence permit; choosing the wrong permit category; relying on outdated legal grounds.Ukrainian practice changes quickly, so what worked before may no longer meet legal requirements. Ignoring changes in legislation and practiceUkraine regularly updates: migration procedures; compliance rules; administrative practice.Foreigners who rely on outdated advice often face problems already at the stage of extending their permits. Passive behavior during migration inspectionsThe most dangerous mistake is doing nothing. Ignoring requests, notices, or inspections often results in automatically negative decisions by state authorities. Legal support mattersWINNER Law Firm sees the same pattern: residence permits are cancelled not because of serious violations, but due to avoidable legal mistakes. The firm’s migration lawyers work with: foreign investors; business owners; top managers; employees of Ukrainian companies.The main focus is risk prevention rather than “firefighting” after the fact. Confidential legal risk assessmentIf you: plan to extend your residence permit; run a business in Ukraine; work as a director or key employee;👉 Request a confidential legal risk assessment before any problems arise.WINNER Law Firm is legal certainty for foreigners in Ukraine. Author: Ihor Yasko, Managing Partner of WINNER Law Firm, PhD in Law. https://youtu.be/zijqlf6Oa1E?si=jL2eVZpFpgQCuQ21

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Buying Property in Ukraine as a Foreigner: What You Don’t See

Ukraine attracts foreign buyers with competitive prices.However, the low entry threshold often hides high legal risks. Typical hidden issues include:· violation of the designated land use;· invalid construction permits;· defects in the chain of title transfer;· encumbrances and court disputes. Many issues remain invisible at the stage of notarizing the transaction. Why legal due diligence is criticalProper legal analysis protects:· ownership rights;· investment value;· the possibility of further sale;· the lawfulness of the origin of funds. Legal realityIn Ukraine, real estate mistakes are corrected:· in the courts;· over many years;· with an unpredictable outcome.​ What WINNER offers:· comprehensive legal due diligence;· transaction structuring;· investment protection strategies;· risk minimization before signing the contract.​ 👉 Proper legal due diligence is not an expense. It is insurance for your investments. Author: Ihor Yasko, Managing Partner of WINNER Law Firm, PhD in Law. https://youtu.be/zijqlf6Oa1E?si=jL2eVZpFpgQCuQ21

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Why foreign investors face criminal cases in Ukraine — and how to stop escalation

Many foreign investors believe that criminal cases start with arrests.In Ukraine, most of them begin quietly and imperceptibly.​ Common triggers include:· business conflicts;· tax disputes;· battles for corporate control;· complaints from partners or competitors. The early stages often look safe until the situation suddenly changes. The most dangerous mistake is waiting. Silence and passivity are often perceived as:· acknowledgment that risks exist;· lack of a defence strategy. How escalation happens:· informal inquiries →· formal proceedings →· searches, seizures, and travel restrictions.​ WINNER’s defence strategy includes:· early risk assessment;· legal positioning before escalation;· protection of executives and business owners;· professional interaction with law‑enforcement authorities.​ 👉 Criminal defence starts even before the first questioning. Author: Ihor Yasko, Managing Partner of WINNER Law Firm, PhD in Law. https://youtu.be/zijqlf6Oa1E?si=jL2eVZpFpgQCuQ21

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Tax residency in Ukraine: why the number of days is not the main factor

Many foreigners believe that tax residency depends only on the number of days spent in Ukraine. This assumption is dangerous because it does not reflect the actual approach of the tax authorities. How Ukraine determines tax residencyThe tax authorities analyse: the centre of vital interests; business activity; economic presence; place of management and control.​ Physical presence is only one of the factors, not the sole criterion. High‑risk scenariosSituations are particularly risky when a person: is a director of a Ukrainian company; effectively manages a business from within Ukraine; receives income from Ukrainian sources; has assets or family ties in Ukraine. The result may be unexpected recognition as a Ukrainian tax resident and an obligation to declare worldwide income.​ Why this mattersTax residency issues usually surface: during tax audits; in the course of bank financial monitoring; after automatic exchange of information between states. At that stage, options to adjust the structure are significantly limited. WINNER Law Firm’s approachThe focus is on: preventive tax structuring; tax residency risk analysis; application of double tax treaty provisions.​ 👉 Tax planning should be proactive, not defensive when the problem has already arisen. Author: Ihor Yasko, Managing Partner of WINNER Law Firm, PhD in Law. https://youtu.be/zijqlf6Oa1E?si=jL2eVZpFpgQCuQ21

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How to Open an LLC in Ukraine as a Foreigner: Legal Reality vs Promises

“Company registration in Ukraine in 24 hours” sounds attractive, but for foreigners it is often a legal illusion.In practice, foreign founders face risks that local entrepreneurs do not have. What foreigners usually do not expect Restrictions for a foreign director A foreign director usually needs: legal grounds to stay in Ukraine; a residence permit; a work permit. Without a properly structured company, the entity may formally exist but cannot operate legally. Banking and AML problems Ukrainian banks apply enhanced compliance to companies with foreign owners: checks of the source of funds; verification of beneficiaries; business model analysis. Incorrect corporate structuring often leads to blocked bank accounts. Tax risks and tax residency Foreign founders often unintentionally create: risks of being treated as a permanent establishment; Ukrainian tax residency; double taxation issues. Speed without strategy leads to tax consequences. Legal reality Company registration is not a technical service.It is a legal decision with long-term consequences. How WINNER Law Firm works Legal structuring of the business before registration. Director and shareholder compliance. Corporate documents aligned with banking requirements. Ongoing legal and tax coordination. 👉 Setting up an LLC correctly from day one is cheaper than fixing mistakes later. Author: Ihor Yasko, Managing Partner of WINNER Law Firm, PhD in Law. https://youtu.be/zijqlf6Oa1E?si=jL2eVZpFpgQCuQ21

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The government has decided to introduce automatic military registration of Ukrainians

Automatic military registration from the age of 18 is not about “instant mobilization” but about the systemic digitalization of data on conscripts and reservists. At the same time, the government’s decision significantly changes the balance of responsibility between the citizen and the state in the sphere of defence duty. Regulatory basis and essence of the changesThe Cabinet of Ministers has adopted a resolution introducing automatic military registration of male citizens of Ukraine starting from the moment they reach the age of 18. In essence, this is an experimental project that integrates data from a number of state registers with the Unified State Register of Conscripts, Military Liable Persons and Reservists.The key innovation is that a person acquires the status of a conscript without personally applying to the Territorial Recruitment Center or submitting paper documents, as everything is carried out on the basis of data already held by the state. Who is registered and howFirst, young men who did not register for military service at the age of 17 automatically acquire conscript status from the moment they turn 18, without any additional actions on their part. Second, men aged 18–60 who are abroad are registered automatically when they obtain or exchange passport documents at units of the State Migration Service.Separately, the mechanism applies to persons aged 18–60 who have never previously been on the military register without lawful grounds: their data are retrieved from the relevant registers and recorded centrally. Technical architecture and data sourcesThe automatic registration system is based on electronic information interaction between the Ministry of Defence and other public authorities. It uses data from the State Migration Service, the demographic register, the civil status acts register, tax authorities, the Pension Fund, the Ministry of Education, the State Border Guard Service and other state registers.This approach helps to avoid duplication of information and reduces the number of errors, since the same person should not appear in the system with different statuses or personal data. Digital services: “Reserv+” and e‑documentsThe reform of automatic registration is linked to the overall digitalization of military records. The updated “Reserv+” mobile application provides access to an electronic military registration document (Reserve ID) that contains up‑to‑date information, including a photo for holders of biometric passports.It is expected that in future citizens will be able to check their status, receive notifications and, potentially, submit certain applications remotely via digital services, minimizing the need for physical contact with the Territorial Recruitment Centers. Reducing bureaucracy and the workload on recruitment centersThe government emphasizes that automatic registration should reduce queues and the number of personal visits to Territorial Recruitment Centers. Some procedures that previously required paper applications, certificates and personal presence are being shifted into a “by default” mode based on data that the state already has.This also corresponds to the stated goal of reducing the workload on recruitment centers by automating basic operations, from registration to updating personal data. Impact on citizens in Ukraine and abroadFor those living in Ukraine, the key change is that failure to visit a Territorial Recruitment Center at 18 no longer means the absence of military status – registration will take place automatically. Accordingly, the argument “I did not have time to register” loses legal significance, since the state itself creates the record in the register.For citizens abroad, the link to passport procedures means that any issuance or exchange of a document will be accompanied by automatic registration without the need to visit Ukrainian consular offices for separate military‑registration actions. Risks, privacy issues and data protectionThe concentration of a large volume of personal data in a single register increases the risks of unauthorized access and data leaks. Given the sensitive nature of military‑registration information, this raises questions about the proper level of cybersecurity, access audits and transparency in working with such data.Another important issue is compliance with the principle of data minimization: the amount of information exchanged between authorities must be proportionate to the purpose of maintaining the register and not turn into the creation of a universal “dossier” on every citizen. Legal consequences of automatic registrationAutomatic registration is not the same as automatic mobilization; it is only the recording of status and entry into the relevant register. At the same time, from the moment a person acquires the status of conscript or military liable, they are fully bound by the obligations to update their data, respond to call‑up notices and comply with other legal requirements.Ignoring the obligation to update information or evading statutory duties may entail administrative or criminal liability, and a reference to “failure to submit an application for registration” will no longer be a convincing argument, as the system operates automatically. Expected effect on defence capabilityThe launch of automatic military registration should provide the state with more complete, up‑to‑date and structured information about its human mobilization resources. This will make it possible to plan mobilization measures, reserves and rotations based on reliable figures rather than fragmented data that depend on citizens’ own activity.In the long term, the combination of automatic registration, digital services and integrated registers may form the basis for a more predictable and targeted mobilization policy, where management decisions are taken on the basis of high‑quality analytics rather than manual record‑keeping. Author: Svitlana Krutorohova, attorney at the law firm “Winner Law Firm”.If you have any questions or issues related to automatic military registration, mobilization or updating your personal military records, you should seek individual legal advice. WINNER Law Firm will help assess your specific situation, identify the risks and build a lawful strategy of conduct taking into account the latest legislative changes. https://youtu.be/WU7J13eUo6U?si=8INcaC2VocL8D9vH

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