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Decision on refusal of banking services. What to do?

In Ukrainian banking practice, decisions to refuse services to a client are not uncommon. Banks act on the basis of the Law of Ukraine “On Banks and Banking Activities”, the Law “On Prevention and Counteraction to Legalisation (Laundering) of the Proceeds of Crime, Terrorist Financing and Financing of the Proliferation of Weapons of Mass Destruction” (hereinafter – the Law on Financial Monitoring) and regulations of the National Bank of Ukraine (NBU).​ The most common grounds for refusal are as follows: impossibility to conduct identification or verification of the client; existence of indications of risky activities of the client (for example, fictitious transactions, inconsistency of the sources of funds); insufficient documentary confirmation of the sources of income or business activity; inclusion of the client in lists of persons related to terrorism or subject to sanctions;​ refusal of the client to provide information or documents requested by the bank. The bank must have documentary grounds, and its decision must be based on internal policies adopted to comply with NBU requirements. Vague wording such as “the transaction is of a risky nature” without further explanation does not meet the principle of transparency and may be challenged.​ Typical refusal situations Refusal to open an account. The bank may decide not to enter into a banking services agreement if the results of risk assessment indicate a threat of involving the institution in money laundering.​ Blocking or closing an existing account. This often occurs during transaction monitoring if the bank considers the operations “risky”.​ Refusal to execute a transfer or payment transaction. As a rule, this is accompanied by a request to provide additional documents confirming the economic substance of the transaction. Termination of relations within a compliance programme. Some banks introduce internal “zero tolerance” policies regarding certain industries or counterparties, which may also affect bona fide clients. Client’s rights Ukrainian legislation provides that a bank may not act arbitrarily. The client has the right to: receive a written notice of refusal indicating the grounds (Article 64 of the Law on Banks and Banking Activities);​ demand justification of the decision and a copy of the internal document on which it is based; challenge the bank’s actions before the NBU or in court;​ apply to the Business Ombudsman Council or the NBU with a statement about violation of the principles of fair servicing. If the bank refuses without sufficient justification or fails to respond to a written request, such conduct may be qualified as a violation of the rights of a consumer of financial services.​ How a client should act in case of refusal Request a written decision. The bank is obliged to provide a document clearly setting out the grounds. Oral explanations or letters without reference to legal provisions or internal procedures are not sufficient. Analyse the stated reasons. Check whether the grounds actually comply with the Law on Financial Monitoring or NBU Regulation No. 65. For example, the statement “it is impossible to establish the origin of funds” presupposes that the bank has previously requested supporting documents.​ Prepare explanations and additional documents. These may include contracts, tax returns, bank statements, invoices. Documentary confirmation of the economic substance of transactions often resolves the bank’s concerns. File a complaint with the NBU. The complaint should indicate: the date of receipt of the refusal, a brief description of the situation, copies of correspondence and documents supporting your position. The National Bank may verify the bank’s compliance with financial legislation.​ Consider judicial protection. If the refusal has caused actual losses – for example, working capital of an enterprise has been blocked – it is advisable to file a claim for damages or for recognition of the bank’s actions as unlawful. Recent case law contains positive examples where clients have successfully restored their rights.​ In parallel, open an account with another bank. Ukrainian law does not limit the number of accounts, so refusal by one bank does not deprive you of the possibility to cooperate with another. Court practice Courts increasingly take the side of clients in disputes with banks. Commercial courts, for example, recognise closure of accounts without documented risk assessment as unlawful. In its decisions, the Supreme Court emphasises that a refusal must be not only formal but also reasoned, with indication of factual circumstances.​ In cases where banks restricted access to funds for reasons not supported by evidence, courts obliged them to resume servicing and compensate losses. This forms a legal benchmark: the client is not the weaker party and is fully entitled to demand observance of legality and equality of the parties.​ Role of the NBU and supervision The National Bank does not interfere with business decisions of banks but monitors compliance with the principles of financial monitoring, transparency and non‑discrimination of clients. If the supervisory authority identifies violations, it may impose sanctions ranging from a written warning to a fine or even revocation of the banking licence.​ Clients who lodge complaints supported by clear evidence (copies of letters, statements, bank notifications) help the NBU identify systemic problems in the financial sector. Therefore, an active legal position is an important element in protecting one’s interests.​ How to prevent refusal Problems can be avoided by following “compliance literacy” principles in advance: Regularly update information about the company with the bank: incorporation documents, ultimate beneficial owners, type of activity. Respond promptly to requests from the compliance department. Ignoring a request often automatically raises the risk rating. Ensure real cash flow consistent with the company’s business activities. Mass transit or dubious transactions without economic substance are the most frequent reason for blocking. Ensure transparency of accounting and tax records, which reduces suspicions of money laundering. Conclusion and contact information A bank’s decision to refuse servicing is not a final verdict. Ukrainian legislation guarantees every client the right to a reasoned response, the possibility to challenge the decision and to restore justice. Timely reaction, proper evidence and professional legal support are the best strategy in such situations.​ Author – Yuliia Popadyn, attorney of the tax and customs law practice

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NAZK. Declaration. Violations. How to act

The system of financial control over the income and expenses of public officials is one of the key pillars of integrity in public service. In Ukraine, this control is exercised by the National Agency on Corruption Prevention (NACP), which is authorised to verify declarations, detect violations and bring reporting entities to account. Role and powers of the NACPThe NACP is a central executive authority with a special status whose main task is to prevent corruption in the public sector. In particular, the Agency:​ organises and supervises the submission of electronic declarations; conducts logical, arithmetic and full verification of submitted data; issues reasoned conclusions on the presence or absence of signs of violations; informs NABU or other law‑enforcement bodies if signs of a criminal offence are detected; carries out lifestyle monitoring of public officials.​In essence, the NACP is a watchdog of honesty and transparency within the public administration, which not only pursues corrupt practices but also promotes a culture of public integrity.​ Who must file a declarationThe duty to file an annual declaration is established by the Law of Ukraine “On Prevention of Corruption”. Declarations must be submitted by:​ civil servants; officials of local self‑government bodies; military personnel (except for conscripts); judges, prosecutors, investigators; members of parliament, members of the Verkhovna Rada of Ukraine and local councils; candidates for elective offices; persons performing functions of the state or local self‑government under contracts or delegated powers.​This list is quite broad, and misunderstanding of one’s own status often becomes a reason for formal violations. Types of declarations and deadlinesThere are the following types of electronic declarations: -Annual – filed by 31 March of the year following the reporting year. -Before dismissal – filed no later than the date of termination of powers. -After dismissal – filed one year after termination of activity. -Before taking office – filed before the start of performing official duties. -Candidate’s declaration – filed when participating in open competitions.Most violations are linked to missed deadlines, since the law does not allow any “leniency” due to technical problems or human error.​ Typical violations in the field of declarationAmong the most common violations are: Late submission of a declaration; even a delay of one day constitutes an administrative offence. Submission of inaccurate information, including concealment of assets, income, expenses or understatement of property value. Intentional failure to submit a declaration, which in case of repeated violation or a significant gap between declared and actual income may give rise to criminal liability. Breach of rules for storing declarations or interference with the system.It should be remembered that the NACP does not just check figures: the system automatically compares declared data with information from state registers of property rights, banking systems, tax databases and other sources.​ Types of NACP checksThe NACP may conduct: logical and arithmetic control, which is carried out automatically after a declaration is submitted; full verification, if there are suspicions that the data in the declaration is inconsistent; lifestyle monitoring aimed at identifying discrepancies between the actual standard of living and declared income.​The result of verification may be either a conclusion on the absence of violations or an act stating that inaccurate information has been detected, which can serve as a basis for referring the materials to court.​ Administrative and criminal liabilityLegislation provides for different levels of liability. Administrative liability involves fines ranging from 850 to 51,000 UAH for late submission of declarations or incomplete or inaccurate data. Criminal liability applies to intentional submission of inaccurate information in an amount exceeding 1.3 million UAH or intentional failure to submit a declaration, with penalties including restriction of liberty for up to 2 years or a ban on holding certain positions. In addition, the existence of a conviction or administrative record may be grounds for dismissal or suspension from official duties.​ What to do in case of a violationIf it is discovered that a declaration was submitted with errors or in breach of deadlines, action must be taken immediately: -Notify the NACP independently via the electronic cabinet, explaining the circumstances; voluntary correction of mistakes is often treated as a mitigating factor. -Submit a corrected declaration; the law allows changes to be made within 7 days after filing the previous one. -Collect evidence confirming the reasons for the violation, such as technical failures, illness or business travel. -Seek legal advice; a competent lawyer will help minimise the risk of administrative or criminal liability.​If the NACP has already launched a verification, its requests should not be ignored, since active cooperation can significantly mitigate the consequences.​ Preventing violationsThe best strategy is to avoid violations at the stage of preparing the declaration. To this end, it is advisable to: regularly update information on personal and family assets, income and liabilities; keep records of major financial transactions (purchase of real estate, vehicles, securities, etc.); use official NACP clarifications or specialised guides; check the accuracy of all entries in registers before submitting the declaration; involve consultants or public‑sector compliance specialists.​Proper organisation of the declaration process is not only a guarantee of avoiding sanctions but also a demonstration of transparency and personal integrity. ConclusionThe NACP is not a repressive body but primarily a preventive institution whose activities are aimed at strengthening public trust in the state and its representatives. Timely and properly submitted declarations are an indicator of professional responsibility for everyone performing public functions. Compliance with financial control rules is not a mere formality, but an element of the transparency culture shaped by Ukraine’s modern anti‑corruption policy.​ Author – Svitlana Krutorohova, Attorney at the law firm “Winner Law Firm”.If you have any questions or issues related to declarations, NACP checks or obtaining advice on liability, the lawyers of Winner Law Firm will help protect your rights, gather the necessary evidence and prepare a legal position to defend your interests. https://youtu.be/J9EOsCgwkfQ?si=ysSWuLzAon3FKlJm

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NACP inspections: What you need to know

The National Agency on Corruption Prevention (NACP) is a key body of Ukraine’s anti-corruption infrastructure, which not only oversees compliance with financial control requirements, but also monitors lifestyles, verifies declarations, conflicts of interest, and related areas of ethical conduct of officials. In recent years, the agency’s approaches have become more systematic, and the circle of persons who may be subject to verification has expanded. Therefore, every declarant must know what exactly the NACP checks, how the procedure is carried out, and what rights a person under inspection has. Legal grounds for inspectionsThe NACP’s activities are regulated by the Law of Ukraine “On Prevention of Corruption” and a number of by-laws, in particular the Procedure for conducting a full verification of declarations of persons authorized to perform functions of the state or local self-government. These rules define the main types of inspections, the procedure for initiating them, and the time limits for their conduct. According to the law, the NACP has the right to conduct the following types of inspections: Automated logical and arithmetic control of declarations. This is the initial stage of verification, carried out automatically on the basis of an electronic declaration. Algorithms identify declarations with signs of inconsistencies or risks. Full verification of declarations. Appointed by the NACP selectively or in the presence of risks of inaccurate declaration, indications of a conflict of interest, or significant discrepancies between income and assets. Monitoring of lifestyle. Verification of the conformity of the declarant’s actual standard of living with declared income. The NACP may conduct observations, analyze information from open sources, or request data from state bodies. Verification of a potential or actual conflict of interest. Conducted upon receipt of information about possible violations of restrictions established by anti-corruption legislation. Grounds for initiating an inspectionAn NACP inspection may be initiated automatically (based on algorithmic risk analysis) or manually, upon applications from citizens, subjects of journalistic investigations, or on the basis of official reports of corruption manifestations. Typical grounds include: Detection of discrepancies between declared income and actual data of tax authorities. Data from open sources about acquisition of property or assets that exceed official income. Information about possible violations of restrictions on combining positions or receiving gifts. A conflict of interest that may arise in the exercise of official powers. At the same time, it is important that the declarant must be informed about the start of a full verification, and the process itself is carried out in compliance with procedural safeguards. Rights and obligations of a person during verificationA person subject to verification has a number of procedural rights: To receive notification of the start of verification. To submit written explanations, additional documents, or supporting information. To use legal assistance. To demand compliance with time limits and confidentiality of data. At the same time, the law provides for obligations: to provide reliable data at the NACP’s request, not to obstruct the inspection, and to provide requested information in a timely manner. Failure to provide explanations or documents may be considered obstruction, which constitutes a separate administrative offense. Procedure for full verification of a declarationA full verification lasts up to 120 days and may be extended for another 60 days. It includes: Analysis of the accuracy of the submitted information. Verification of the existence of a conflict of interest. Clarification of the conformity of lifestyle to income. Examination of the sources of origin of assets. The NACP has the right to obtain information from state registers, banks, tax authorities, as well as to use interagency requests. If the agency identifies significant inconsistencies, it may apply to law enforcement bodies or a court. The results of the inspection are formalized in an NACP opinion, which establishes whether a violation is present or absent. Based on its results, the following are possible: Referral of materials to NABU, the SBI, or the police. Drawing up a protocol on an administrative offense. Submission of a proposal to the head of the institution to eliminate the violation. Consequences of inspection resultsIf the fact of failure to submit a declaration or submission of inaccurate information is established, liability arises – administrative or criminal, depending on the amount of unjustified assets or the degree of distortion of information. Criminal liability (Article 366-2 of the Criminal Code of Ukraine) arises in the event of knowingly submitting inaccurate data in a declaration in an amount exceeding 1.3 million UAH or intentional failure to submit a declaration.Administrative liability (Article 172-6 of the Code of Ukraine on Administrative Offenses) applies if the inaccurate information is below this threshold. In addition, the detection of unjustified assets may be grounds for initiating proceedings in the High Anti-Corruption Court and confiscation of property. Lifestyle monitoring: a thin line between control and interferenceOne of the most delicate areas of the NACP’s activity is lifestyle monitoring. In practice, the agency may analyze publications on social networks, journalistic investigations, and data from open cadastral or transport registers. If an obvious discrepancy between lifestyle and income is detected, the NACP initiates a request to the declarant demanding an explanation of the source of funds. Such actions are particularly relevant for officials who declare minimal income but show signs of significant expenditures, such as purchase of luxury housing, cars, or jewelry. At the same time, legislation requires the NACP to maintain a balance between the right to privacy and the public interest in control. Practical tips for declarants Check data before submitting a declaration. Reconcile information on income, real estate, corporate rights, and vehicles. Keep documents. Proof of ownership or sources of income may be decisive in case of an inspection. Respond promptly to NACP requests. Ignoring or delaying a response worsens the situation. Consult a lawyer. Professional support helps avoid careless explanations or procedural mistakes. Avoid formal violations, such as late submission of a declaration or failure to promptly report significant changes in property status. ConclusionNACP inspections are an integral part of the anti-corruption prevention mechanism, aimed not only at punishment but also at fostering a culture of

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The State Budget Law has been published: key innovations

The Law on the State Budget of Ukraine for 2026 has already been published and effectively sets the “financial rules of the game” for the state, business and citizens for the next year.The document preserves the wartime priority while strengthening the social component, support for communities and certain incentives for the economy. Key macro indicators and deficitBudget‑2026 provides for state budget revenues at 2.9046 trillion UAH (about 2.61 trillion UAH of the general fund), which is over 400 billion UAH more than planned for 2025.Expenditures amount to about 4.77 trillion UAH, forming a significant deficit of around 1.9 trillion UAH, or more than 18% of GDP, which is planned to be covered by domestic resources and international assistance. State debt in 2026 is projected to exceed 10.4 trillion UAH (over 100% of GDP), confirming the trend of high debt dependence typical for wartime.The Government directly links budget sustainability to the continuation of cooperation programmes with international partners and maintaining discipline in the tax sphere. Social standards: minimum wage, subsistence minimum, tax social benefitOne of the most tangible blocks for citizens is the increase in basic social standards.From 1 January 2026 the minimum wage is set at 8,647 UAH, and the general subsistence minimum at 3,209 UAH, which affects the size of benefits, fines, alimony, court fees and other payments pegged to these indicators. Tax indicators are also revised: the level of the tax social benefit is set at 1,664 UAH, which affects payroll calculation and the burden on employers with low‑paid staff.For sole proprietors (FOP) the income limits under the simplified taxation system are changing, which is important for those operating in the micro and small business segment. Revenue structure: focus on turnover‑based taxesThe main sources of income remain indirect taxes and personal income taxes.A significant increase is planned in VAT on imports (over 680 billion UAH), VAT on goods and services produced in Ukraine (over 390 billion UAH), and revenues from personal income tax and military levy (over 560 billion UAH). This focus means that the state continues to rely on taxing consumption, imports and payroll rather than targeted capital taxes.Together with adopted or planned changes on taxation of digital platforms, the so‑called “OLX tax”, and certain excises (for example, on sugary drinks), Budget‑2026 shapes a stricter but more controllable fiscal base. Expenditures: defence, security and resilienceThe expenditure structure confirms that defence and security remain the key priorities, with a record amount of funds directed to these areas, exceeding half of the general fund resources.At the same time, funding is increased for sectors that ensure state resilience in wartime: energy, critical infrastructure, digital services and community support. This balance means that businesses and citizens will operate under high tax pressure while relying on state support in key areas such as access to finance, recovery and compensation for losses.For local self‑government bodies, Budget‑2026 effectively sets the framework for development at community and regional level, as a significant share of resources remains centralised. Social support and new programmes for the populationThe social block is significantly strengthened: spending on social support for citizens increases by more than 10%, to around 465–467 billion UAH.Within this scope several major programmes are highlighted: assistance to internally displaced persons, basic targeted support, benefits and subsidies, payments to vulnerable groups, support for persons with disabilities, care services and other social policy instruments. Special emphasis is placed on supporting families with children: the one‑time allowance at childbirth increases to 50,000 UAH, and the monthly childcare allowance for children under one year rises to 7,000 UAH.The “eRecovery” and “HOME” programmes continue the line of compensation for damaged and destroyed housing, which is critical for households affected by hostilities. Healthcare, education and scienceHealthcare expenditures include traditional programmes financed through the National Health Service of Ukraine as well as specific “targeted” initiatives.These include substantial funding for centralised procurement of medicines for cancer patients, patients with cardiovascular diseases and people with orphan diseases, as well as a new preventive health screening programme for people over 40, with a targeted payment of 2,000 UAH for medical examination. The education component of the budget not only increases total funding but also reshapes the approach to financing communities.Part of the resources is allocated to subventions for basic educational needs, infrastructure modernisation and support of public investment projects to help communities maintain schools and ensure their energy resilience and safety.For science, increased funding is envisaged according to the “money follows results” principle, and funds are allocated to create defence research centres. Support for business, agriculture and communitiesBudget‑2026 includes a block of business support instruments that have already become “traditional” for the war years: the “5‑7‑9%” programme, “eOselya” (affordable mortgage), support for defence and innovative projects.In total more than 40 billion UAH is earmarked for such tools to stimulate investment, housing purchases and the development of high‑tech sectors. Separate resources are provided for the agricultural sector to support farmers through credit programmes, per‑hectare subsidies and livestock support, as well as humanitarian demining of agricultural land, which is essential for restoring production.Local budgets receive transfers in the form of basic grants and a range of subventions (for education, child nutrition, social protection and infrastructure projects), although their real autonomy and development potential remain largely constrained by the parameters of the state budget. New fiscal accents and challenges for taxpayersBudget‑2026 increases the tax burden not only by expanding the base (imports, payroll) but also through new tax initiatives – in particular excise duties on specific categories of goods (such as sugary drinks) and legislative changes to the taxation of digital platforms.Combined with strengthened financial monitoring and expanded automatic exchange of information, this significantly narrows the room for “grey” schemes and increases risks for non‑compliant taxpayers. For businesses this is both a challenge and an opportunity: on one hand, higher compliance costs, adaptation of accounting systems and work with risk‑based control criteria; on the other hand, more predictable rules, access to state support programmes, the possibility of reserving employees under updated wage criteria and participation in public projects.For citizens

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The Economic Security Bureau of Ukraine continues to uncover tax evasion

The Economic Security Bureau of Ukraine (ESBU) is showing a stable trend towards increasing the number of proceedings for tax evasion, focusing on complex, systemic schemes and significant amounts of losses to the state budget. For businesses this means a fundamentally new level of attention to tax risks, particularly to business “fragmentation”, undeclared income and understatement of the tax base.​ New ESBU focus Over the past few years, investigations of tax evasion have gradually become one of the key areas of the ESBU’s work, both in terms of the number of proceedings and the intensity of investigative actions. Statistics indicate a rise in criminal proceedings for tax offences, as well as an increase in notices of suspicion and asset seizures in such cases. At the same time, the volume of covert investigative actions is growing – wiretapping, account monitoring, surveillance – creating a new reality for business in which “grey” tax optimisation is increasingly subjected to criminal scrutiny rather than mere additional tax assessments. This approach meets the demand for de‑shadowing the economy but also amplifies the risk of coercive pressure on taxpayers operating in high‑risk segments. Typical evasion schemes One of the most notable trends is the fight against business “fragmentation”, where a chain of shops or services is formally split into dozens of sole proprietors or small entities in order to keep simplified taxation and avoid VAT or higher income tax rates. In practice, such structures are fully controlled by the same owners, operate under a single brand and essentially function as one business, which the ESBU qualifies as deliberate large‑scale tax evasion. Another common category of cases involves the use of foreign platforms, intermediaries and non‑resident accounts to move revenue abroad with its subsequent “return” as alleged information or intermediary services. In such models a portion of actual income is intentionally not declared, resulting in tens of millions of hryvnias in unpaid taxes, and the organisers’ actions are qualified under Part 3 of Article 212 of the Criminal Code of Ukraine, with additional qualification for money‑laundering and use of forged documents. Sectoral overview Practical ESBU cases include matters in the fuel sector, where company officials understate real fuel‑sales income by tens of millions of hryvnias, leading to substantial underpayment of corporate income tax and VAT and subsequent asset seizures to secure damage recovery. In other regions, the ESBU records evasion schemes based on fragmentation of retail chains, where more than a hundred controlled sole proprietors are used to minimise tax liabilities and to support parallel smuggling of equipment. Illustrative examples are also found in manufacturing and processing, where tax evasion is accompanied by significant seizures of inventory and other assets, and in some cases tens of millions of hryvnias are returned to the budget through paid taxes and confiscated assets. Such stories are actively communicated via ESBU official channels and the media, signalling to business that large amounts and systemic schemes have become priority targets for detectives. Statistics and legal consequences Official ESBU data show that the number of criminal proceedings involving tax offences is in the thousands, and the share of tax crimes is among the highest in the Bureau’s case‑load. The number of court warrants for covert investigative actions and asset seizures is also increasing, indicating a shift towards a more aggressive strategy for documenting evasion schemes and ensuring actual recovery of losses.​ For specific taxpayers the consequences may include the opening of criminal proceedings under Article 212 of the Criminal Code of Ukraine, as well as restrictions on access to assets, account blocking and the risk of suspicion being served on managers and beneficial owners. In some cases, a person may be released from criminal liability if all losses are fully compensated, but this does not negate the reputational and financial damage incurred during the investigation. How business should adapt Current ESBU practice shows that the highest risks arise from models based on artificial business splitting, misuse of the simplified tax regime, off‑the‑books wage payments, and non‑transparent cross‑border settlements. Businesses that continue to rely on such approaches should expect not only additional tax assessments but also criminal‑law consequences for owners, directors, and key officers.​ A compliance strategy for 2025 should include an audit of the corporate structure, an analysis of transactions with non‑residents, verification of salary transparency, as well as readiness to communicate with the ESBU and defend the company’s position within the legal framework. It is important to involve legal advisers in a timely manner who can assess the criminal‑law risks of the business model, develop an action plan in the event of searches or asset freezes, and build an evidentiary basis confirming the lawfulness of the company’s tax conduct.​ Author: Ihor Yasko, Managing Partner at WINNER Law Firm, PhD in Law.​ If you have any questions or issues related to tax risks, interaction with the ESBU, criminal proceedings under Article 212 of the Criminal Code of Ukraine, or the need for a comprehensive audit of your business model, contact the Winner Law Firm team for an individual consultation and protection of your interests. https://www.youtube.com/watch?v=m5aS_Sby2c8

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New rules for preparing work completion certificates

The act of completed works (services rendered) remains one of the key primary documents confirming the fact of a business transaction. It is this document that forms the basis for accounting of expenses, tax credit, and determining the moment of revenue recognition. In 2025, the rules for its execution underwent significant changes as part of the reform of approaches to primary documentation and the transition of businesses to digital accounting formats. Regulatory frameworkThe procedure for executing acts of completed works is traditionally regulated by the Law of Ukraine “On Accounting and Financial Reporting in Ukraine” No. 996‑XIV, the Tax Code of Ukraine (Articles 44, 198, 201), as well as sectoral accounting standards. In addition, starting from 2025, the amendments introduced by Order of the Ministry of Finance of Ukraine No. 388 of 17 September 2024 entered into force, updating the requirements for the requisites of primary documents and the procedure for their maintenance. The key focus is on eliminating duplication of paper and electronic forms, strengthening the legal force of electronic documents, and unifying the requirements for digital signatures. Mandatory details: what remained and what changedAccording to the updated requirements, an act of completed works, regardless of its form (paper or electronic), must contain the following mandatory details: name of the document and its number; date of drawing up; description of the essence of the business transaction (list of works performed or services rendered); unit of measurement, quantity, cost excluding VAT and total amount; signatures (including electronic) of responsible persons of both parties. A new requirement is to indicate in the field “Grounds for drawing up” an exact reference to the contract within which the works were performed. This makes it possible to clearly link the act to a specific obligation and simplifies inspections for both internal and tax control. The list of persons authorized to sign the act has also been expanded: now it may be not only the director or chief accountant, but also an authorized employee under a power of attorney, including one executed in electronic form. Electronic act: legal force and requirementsAn important innovation of 2025 is the full equivalence of an electronic act to its paper analogue. In accordance with the Law “On Electronic Documents and Electronic Document Flow”, a document signed with a qualified electronic signature (QES) has equal legal force and does not require duplication on paper. The new rules provide that the date of drawing up an electronic act is determined by the moment when the last electronic signature is affixed. This is crucial for accounting and tax purposes, as it affects the determination of the period for recognition of income and expenses; in tax accounting, the key date is the date of the counterparty’s last signature rather than the date when the draft act was generated. For employers using cloud services or specialized document‑management systems, there is a technical possibility to store acts on secure electronic platforms that comply with personal‑data protection legislation. Reconciliation of discrepancies and refusal to signThe new rules specify the procedure for reconciling acts and recording refusals to sign. If a party disagrees with the scope or quality of the works, it must notify the other party in writing within five business days from the moment of receiving the act. If the refusal is unsubstantiated or the deadline is missed, the act is deemed agreed and has legal force. In electronic document flow, the same approach applies: if no reasoned objection is received from the counterparty through the electronic exchange system, the act is considered accepted by default. This significantly simplifies business interactions between companies engaged in large‑scale or mass operations. Tax aspects: focus on reliabilityThe tax authorities emphasize that an act of completed works is not an independent basis for recognizing a tax credit, but it is a key piece of evidence confirming that services have actually been rendered. Recognition of expenses and income is possible only if the reality of the transaction is confirmed, meaning that the act must correspond to the parties’ actual actions. Deficiencies in execution, missing mandatory details, or missing signatures may serve as grounds for disallowing expenses or rejecting the tax credit. Therefore, legal entities must ensure proper internal verification of acts already at the stage of their preparation. Practical recommendations for businessTo avoid disputes with counterparties and tax authorities in 2025, lawyers and accountants recommend: ensuring a unified internal template of acts that complies with the updated requirements of the Ministry of Finance; revising contract templates to include provisions on electronic document flow; using only QES issued by certified trust service providers; recording the process of act reconciliation within the corporate document‑management system; checking the correct indication of contracts, scope of works, units of measurement, and value indicators; storing acts for at least three years, regardless of the form in which they are drawn up. Special attention should be paid to documents drawn up with non‑residents: in such cases, translation into Ukrainian and certification of the correspondence of the data to the primary documents of the foreign party are mandatory. Liability for violationsImproper execution of acts may lead to administrative and financial liability. Under Article 164‑2 of the Code of Ukraine on Administrative Offences, violation of the rules for maintaining accounting records and preparing primary documents entails a fine ranging from 8 to 15 tax‑exempt minimum incomes of citizens (from 136 to 255 hryvnias), and in case of repeated violation – up to 425 hryvnias. In the tax sphere, incorrect execution of acts may become grounds for additional assessment of corporate income tax or VAT, and in court it may lead to recognition of the contract as unperformed or to its termination at the customer’s initiative. Prospects of automationTrends show that the execution of acts is gradually moving into a fully digital environment. Starting from 2026, the Ministry of Economy plans to introduce a unified standard of the electronic structure of an act in XML format, which will allow integrating document flow between different accounting systems. This approach will

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How will the tax burden on sole proprietors change in 2026

Tax burden on individual entrepreneurs (FOPs) will increase in 2026: the basic benchmarks (minimum wage, subsistence minimum) are changing, income limits and the actual amounts of mandatory payments are growing, the monthly military levy is preserved, and in parallel the government is moving towards introducing mandatory VAT for single tax payers (“simplified regime”) with annual turnover starting from UAH 1 million. For most entrepreneurs this will mean higher regular payments, tighter control over income and cashless transactions, and a higher likelihood of acquiring VAT payer status.​ Key benchmarks for 2026 The adopted State Budget 2026 raises the minimum monthly wage to UAH 8,647 and the subsistence minimum for able‑bodied persons to UAH 3,328. These figures are the starting point for calculating the maximum single tax rates for Group 1, the minimum unified social contribution (USC), and a number of other fiscal indicators directly affecting monthly payments for FOPs.​ The increase in the minimum wage automatically raises the USC base (22% of the minimum wage) and the range of labor fines, which also affects the “price” of officially hiring employees through an FOP. For a sole proprietor working alone, this means a higher minimum contribution “for oneself”, and for those with hired staff – additional pressure on the payroll fund.​ Single tax and new income limits In 2026 the three main groups of the simplified tax system for FOPs are preserved, but income limits and the effective tax burden change due to the link to updated wage indicators. For Group 1 the maximum single tax rate is up to 10% of the subsistence minimum for able‑bodied persons, which gives up to UAH 332.8 per month in 2026, while for Group 2 it is tied to the minimum wage and may reach 20% of it, i.e. up to UAH 1,729.4 per month, as set by local councils for the year.​ The annual income caps for single tax groups 1–3 also increase: for Group 1 – to about UAH 1.44 million, for Group 2 – to over UAH 7.21 million, and for Group 3 – to roughly UAH 10.09 million. Formally this expands the possibility to stay on the simplified regime with higher turnover, but entrepreneurs face larger one‑off and monthly tax payments and stricter monitoring of compliance with limits.​ USC and military levy for FOPs The unified social contribution for FOPs in 2026 is still calculated as 22% of the minimum wage, but the higher minimum wage pushes the minimum monthly USC amount upward. For an entrepreneur, this means an increased mandatory payment regardless of actual income, unless temporary relief regimes are applied.​ The military levy for simplified taxpayers is fixed as an additional component of the burden: for FOPs in Groups 1, 2 and 4 it is set at 10% of the minimum wage per month, which in 2026 equals UAH 864.70. For FOPs in Group 3, in addition to the 5% single tax rate (or 3% for VAT payers), the military levy is charged on income, which together with USC forms a substantial overall share of gross turnover.​ Move towards mandatory VAT A separate block of changes follows IMF requirements regarding the simplified system, with the main focus on abolishing benefits that allowed high‑turnover FOPs to avoid VAT registration. Under the new cooperation program, FOPs in Groups 2–3 with annual income above an indicative UAH 1 million threshold will have to register as VAT payers, effectively closing the window for operating without this tax at significant turnover levels.​ Although key VAT requirements as a structural “benchmark” are planned for full implementation by late 2026–early 2027, during 2026 businesses will already need to prepare for the new tax model: review contracts, cost structures and pricing, and assess whether it is still beneficial to remain under the simplified regime after exceeding the critical turnover threshold. FOPs in IT, consulting and professional services are considered the most vulnerable, as their current effective tax rate may increase two‑ to three‑fold when switching to mandatory VAT.​ Stronger control and practical implications Alongside higher tax amounts, the state continues to push fiscalization and digitalization of FOP activities, including expansion of mandatory cashless payments and the use of payment services. This enhances turnover transparency but also provides more data for tax and financial monitoring, increasing the risk of audits in cases of atypical transactions or artificial business splitting.​​ In 2026 entrepreneurs will face not only a simple arithmetic increase in single tax, USC and military levy, but also a qualitative shift in state policy: tighter control over limits and cashless receipts and preparation for mandatory VAT once certain turnover thresholds are reached. For FOPs it becomes critical to regularly review their tax model, keep accurate records and plan possible transitions to other regimes in advance to avoid sudden spikes in tax burden.​ Author – Yuliia Popadyn, attorney in tax and housing law at the law firm “Legal Company WINNER”.​ If you have any questions or issues related to changes in the tax burden on FOPs in 2026, choosing the optimal tax regime or preparing for possible mandatory VAT, you can seek individual advice from tax and customs law specialists at the law firm “Legal Company WINNER”. https://youtu.be/rEd6me-Ume4?si=vj-2Pyi978nXeC1v

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The IMF demands an increase in certain taxes: what is behind the latest fiscal change

Ukraine has entered a new stage in its relations with the International Monetary Fund, one of the main sources of external financing that helps the country maintain macroeconomic stability during the war. The latest review of the EFF program confirmed that the IMF continues to support Ukraine but is putting forward new conditions, including the gradual increase of taxes and the narrowing of fiscal benefits.​ This decision has triggered an active public debate: is it appropriate to increase the tax burden in a country whose wartime economy is already operating on the verge of survival and whose businesses are in a state of constant transformation?​ Why the IMF insists on higher taxesThe IMF’s logic is based on the need to restore fiscal balance. In 2024–2025, Ukraine’s state budget deficit exceeded 20 percent of GDP, making it one of the highest figures in the world, with a significant share of needs covered by external grants and loans that cannot last indefinitely.​ The Fund insists that Ukraine should gradually move from external financing to self-sufficiency, which requires higher tax revenues, better administration, the reduction of shadow schemes, and the creation of a stable budget revenue base. As a result, several areas may come under the IMF’s requirements:​ VAT and excise taxes. The possible cancellation of temporary exemptions for certain sectors, particularly agriculture, energy, and IT.​ Personal income tax and unified social contribution. A reduction in the upper thresholds of non-taxable income and the gradual alignment of rates is under discussion.​ Simplified taxation system. The Fund traditionally considers it overly liberal and may insist on its reform or restriction for certain categories of entrepreneurs.​ Goal: fiscal resilience, not “tax pressure”The government is trying to frame the discussion not in terms of “tax hikes” but rather “tax optimization.” The Ministry of Finance emphasizes that the focus is not on increasing the overall fiscal pressure on business, but on a fairer distribution of the tax burden and combating evasion.​ Even during wartime, a significant volume of tax benefits remains in place, reducing budget revenues by tens of billions of hryvnias each year, and some of these incentives are political rather than economic in nature. These are precisely the “gifts” the IMF recommends revising, with the ultimate goal of broadening the tax base while keeping rates moderate.​ Political dimension of the talksIMF financial assistance is not only an economic tool, but also a political one, serving as a kind of guarantee of trust from other donors such as the World Bank, the EU, Canada, and the United States. If the IMF concludes that Ukraine’s tax policy is out of control or artificially lenient toward certain sectors, this may slow down financing from other partners.​ Therefore, the government has to strike a balance: on the one hand, preserving social stability and supporting business, and on the other, maintaining the confidence of international creditors. According to unofficial information, the current compromise implies only a partial increase in specific taxes, coupled with stricter tax administration and further de-shadowing of the economy.​ Potential impact on businessUkrainian business has traditionally viewed any increase in the tax burden with skepticism. Since 2022, entrepreneurs have already endured a series of crisis decisions, from higher military levies to new currency control rules, so even minor tax hikes could prove critical for small businesses under these conditions.​ The greatest concern is caused by the possible reform of the simplified tax system, as hundreds of thousands of entrepreneurs who provide jobs and fund local budgets fear losing their competitive edge. The IMF, however, sees this not as pressure, but as a way to ensure tax equity between sole proprietors and legal entities.​ At the same time, experts stress that, if implemented transparently and with due regard to wartime realities, the changes could even stimulate development. For example, expanding electronic administration tools, eliminating duplicative controls, and introducing automatic refunds of overpayments would help create a more predictable environment for investors.​ Social risks of higher taxesAny tax increase during wartime affects not only businesses but also households. Rising indirect tax rates such as VAT and excise duties inevitably feed into higher prices, raising the risk of accelerating inflation, which already exceeds the National Bank’s targets.​ The government is trying to offset potential imbalances through social support programs for vulnerable groups, but this again inflates budget spending. As a result, the state is treading a fine line between meeting IMF requirements and staying within the real capabilities of the economy.​ Outlook and political responsibilityTax increases always have a political dimension in addition to the economic one, and any misstep can undermine public trust in the government, especially in wartime. The key question therefore is how to implement fiscal changes while preserving legitimacy and public support.​ Gradualism, predictability, and clear communication with society are the three main principles without which even the most rational tax reform can fail. If Ukraine manages to balance IMF demands with its own economic interests, the outcome may be not only financial stability, but also a stronger state sovereignty.​ Author – Maksym Bahniuk, head of the tax and customs law practice at the law firm “Legal Company WINNER”.​If you have any questions or issues related to the application of new tax rules, clarifying IMF requirements, or adapting your business to these changes, please contact the experts at Winner Legal Company, who will help you assess risks and find the best solution for your situation.​ https://youtu.be/rEd6me-Ume4?si=vj-2Pyi978nXeC1v

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Property division. Lawyer

Division of marital property is one of the most conflict‑prone aspects of relationship breakdown, as many spouses rely only on their personal sense of fairness and overlook legal rules, limitation periods, and evidence requirements, which can leave the faster‑reacting but less informed party with far less than family and civil law would actually allow. When the situation is complex, a skilled divorce property lawyer becomes a key figure in determining whether a person can preserve financial stability after divorce.​ Nuances of joint marital property As a general rule, all assets acquired during marriage are considered joint marital property, even if they are formally registered in the name of only one spouse, and this includes not only apartments and cars but also business shares, deposits, investments, securities, expensive items, and corporate rights. In practice, one party often tries to conceal assets, re‑register them to relatives, or present them as premarital personal contributions, and without professional analysis of documents and financial flows it is difficult to prove their joint nature.​ Division of property is further complicated because the law allows deviation from the equal‑shares principle if one spouse avoided contributing to the family budget or acted to the detriment of the family’s interests. This opens opportunities for more flexible protection but also raises the bar for the quality of evidence and legal argumentation, so the lawyer must not only know the rules but also be able to “translate” real‑life circumstances into the language of the court.​ When a lawyer is essential A common mistake is trying to “reach a friendly agreement” and signing any proposed property‑division arrangements without legal review, which can leave the accommodating spouse facing long‑term consequences, especially when housing or a business share is involved. Such agreements are often drafted with serious violations, giving the other party a chance to challenge them later and trigger a second redistribution of assets.​ Another risk is preparing the claim and evidence alone: choosing the wrong method of protection, failing to prove the origin of funds, making errors in the wording of claims, or missing deadlines can lead to the claim being rejected even when the person is substantively right. In these cases, a second chance is not always available, and correcting mistakes later usually takes far more time and money.​ Winner’s expertise in property division Winner Law Firm focuses, among other things, on family and property disputes, combining family law with deep knowledge of corporate and financial instruments, which is critical when marital assets include company shares, business assets, investment portfolios, or complex debt obligations. The firm’s lawyers know how to “unpack” asset structures, determine what is subject to division, and what can be excluded from the marital pool.​ For each case the team conducts a risk analysis, assessing court practice, possible tactics of the other party, prospects of settlement, and financial consequences of each scenario. The client receives not an abstract “legal consultation” but a clear action plan that explains what share of property is realistically achievable and what evidence must be collected, which is especially valuable for entrepreneurs, executives, and high‑net‑worth individuals who cannot afford improvisation.​ Tools to protect the client Winner’s lawyers use the full range of tools, from evidence preservation and registry requests to engaging valuation experts, financial analysts, and, where necessary, criminal‑law mechanisms in cases of fraudulent asset transfers. In matters involving hidden assets they may seek interim measures that block disposal of property until the court issues a decision, significantly reducing the risk of assets being siphoned off.​ Significant attention is paid to pre‑trial settlement: if there is a chance of achieving a favourable settlement, the lawyers draft an agreement that minimizes future disputes and sets out a clear enforcement mechanism. This “peaceful” route is especially important when property division is closely linked to ongoing interaction between former spouses, for example because of children or joint business.​ Why choose Winner First, the firm unites family, corporate, and tax expertise in one team, which matters because property division often triggers issues of title registration, changes in corporate structure, and potential tax consequences, and it is crucial to see the whole picture rather than just the court case. Second, the firm maintains a high standard of communication, so the client always understands the stage of the case, steps already taken, and possible developments.​ Third, Winner’s lawyers work with a strong focus on the client’s reputational safety: property disputes can involve public conflicts, media leaks, and pressure via social networks or business circles, and a competent strategy helps minimize publicity, preserve confidentiality, and prevent a private conflict from destroying a career or business, which for many clients is decisive.​ Starting work with a property‑division lawyer The first step is to contact Winner’s office or submit an online request for consultation, after which at the initial meeting the lawyer clarifies the asset composition and documents, discusses timing, outlines potential scenarios, and proposes a strategy ranging from amicable negotiations to full litigation support. It is vital to grant the lawyers early access to key documents such as sale‑purchase contracts, loan agreements, business registration papers, and bank statements.​ Timely engagement makes it possible not only to formulate claims correctly but also to prevent asset dissipation, block risky transactions, and preserve crucial evidence, giving the client more than just a chance to “win the case” but an opportunity to emerge from a life crisis with their financial foundation as intact as possible and with restored control over their future. This is precisely the outcome the Winner Law Firm team strives to achieve.​ Author — Svitlana Krutorohova, attorney at the law firm “Winner”. https://www.youtube.com/watch?v=cRQXdIrL4_g

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Family lawyer services: how to protect your rights and preserve your dignity in challenging life situations

Family conflicts are among the most emotionally charged and at the same time the most complex legal processes. Issues such as divorce, division of property, determination of a child’s place of residence, or child support collection always involve personal histories, emotions, and financial consequences. In such situations, a family lawyer becomes not only a legal representative but also a strategist who helps a person get through the crisis with minimal losses and maximum legal benefit. Winner Legal Company has deep expertise in the field of family law. Our lawyers protect clients’ interests both in court disputes and at the pre‑trial stage, providing a professional, sensitive, and comprehensive approach to every case. Family law: a high‑risk areaMany people mistakenly believe that family issues can be settled “by verbal agreement”. In practice, an oral understanding often fails the test of time, especially when it concerns joint property or children. For example, in a divorce without written fixation of arrangements, one party may lose the right to a share of joint assets or fail to receive child support provided by law. Family legislation of Ukraine is complex, and even a minor mistake in drafting documents or filing a claim can be costly. The key recommendation is to involve a lawyer not when “the fire has already started” but at the decision‑making stage. Main areas of work of WINNER family lawyers DivorceOur attorneys help clients go through the divorce procedure as calmly as possible. We prepare all necessary documents, represent clients in court, and also look for options for pre‑trial settlement if both parties are open to compromise. Division of marital propertyConflicts most often arise around apartments, businesses, or vehicles acquired during the marriage. The WINNER team analyzes the financial situation, collects evidence, and builds a strategy that enables the client to obtain a fair share. Child support disputesWe assist both those who seek to ensure adequate financial support for a child and those who face excessive demands from the other parent. Our lawyers can substantiate the client’s position in a reasoned manner so that the court decision is both fair and realistic to comply with. Determining the child’s residence and participation in upbringingThese cases are particularly sensitive because they concern what is most valuable—children. WINNER lawyers act in the best interests of the child while at the same time protecting the rights of the mother or father, maintaining a balance between legal formalities and humanity. Prenuptial agreementModern partnership culture increasingly relies on transparent arrangements. Our specialists help draft a prenuptial agreement that guarantees financial honesty and serves as a reliable tool in case of unforeseen circumstances. Establishing or disputing paternityThe firm’s lawyers support DNA examinations and the preparation of applications and claims, ensuring compliance with all procedural deadlines and the rights of all parties. Advantages of working with Winner Legal CompanySystematic and analytical approach. Each case is analyzed in terms of court practice, risks, and psycho‑emotional factors.Confidentiality. In family cases, the client’s information security is an unconditional priority.Individual approach. Even with similar circumstances, each case requires its own strategy.Full‑cycle support. From the initial consultation to enforcement of a court decision, the client is never left alone with the system.Pre‑trial settlement. The aim is to preserve not only the client’s resources but also peace of mind. For many WINNER clients, a family lawyer becomes a long‑term partner—a person they turn to in difficult yet vital situations. How to request assistanceTo receive legal advice, it is enough to schedule a meeting or submit a request via the Winner Legal Company website. During the initial consultation, the lawyer listens to the circumstances, assesses the prospects of the case, and outlines a realistic action plan. The team’s goal is not only to win the case, but also to ensure that the client feels supported, protected, and confident about the future. In family law matters, this is truly priceless. Author – Svitlana Krutorohova, attorney at the law firm “Winner Legal Company”. https://www.youtube.com/watch?v=cRQXdIrL4_g

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