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Regular inspections of companies providing housing and utility services to Ukrainians have revealed large-scale problems that have long concerned both consumers and government authorities. The results of inspections conducted by the State Consumer Service, the Accounting Chamber, and local self-government bodies in autumn 2025 have confirmed systemic violations in the provision of utilities, directly impacting citizens’ quality of life and the fairness of tariff formation. Scale of the problemChecks were carried out in all regions of Ukraine, covering heating companies, water utilities, housing maintenance departments, and companies managing apartment buildings. Oversight agencies recorded violations in over 60% of companies. Most often, these involved poor-quality services—water supply interruptions, low heating temperatures, prolonged delays in fixing emergencies, and the charging of tariffs not corresponding to the actual volume of services provided. According to the State Consumer Service, the most common violations were unjustified overcharging in bills—on average by 10–15%. Nearly a third of companies failed to recalculate for services not provided or provided poorly. In some cases, abuses by leaders of local communal enterprises were recorded, where budget funds were used for non-targeted purposes. Typical violationsKey issues include: failure to meet service quality standards, notably heating temperature and water supply pressure; untimely resolution of emergencies or non-arrival of teams to consumer calls; not issuing official complaint acts upon detecting quality violations; lack of proper accounting of actual company expenses, leading to unjustified tariff increases; breach of contract rules with the public, including providing services without promptly informing consumers of changes. As community representatives note, the typical behavior of providers is to avoid admission of guilt or delay complaint resolutions. This forces citizens to turn to the courts or the National Energy and Utilities Regulatory Commission (NEURC). Arguments from regulatorsExperts believe the problem is systemic. Outdated equipment, lack of investment, energy losses, and imperfect tariff policies create conditions for chronic abuse. “Most water utilities and heating companies operate on the edge of survival, but this does not release them from compliance with statutory quality standards,” authorities say. At the same time, the state acknowledges that utility sector oversight requires modernization. In 2025, the government launched a digital housing and utilities monitoring reform via a centralized “Public Utilities Analytics” platform, enabling real-time tracking of tariffs, consumption, and emergencies. The goal is transparency, since most violations relate to manual data adjustments or schemes for extra billing on unaccounted services. Provider responsibilityLegislation provides several mechanisms to address offending companies. According to the Law of Ukraine “On Housing and Utilities” (Article 27), a consumer may lodge a formal complaint if a service is delivered poorly or incompletely. The provider must then recalculate within a month. Repeated violations incur fines or loss of license. In practice, these mechanisms only partially work—given the unequal positions of consumers and monopolists. Special attention was given to utilities lacking sufficient funds for modernization. The commission found that over 40% of violations were not intentional actions but a result of funding shortages and lack of asset renewal. On local authority decisions, these companies were obliged to develop technical upgrade plans and undergo public expenditure audits. Local government responseMany city councils have initiated independent public oversight commissions. Such commissions operate in Kyiv, Lviv, Kharkiv, and Dnipro, including representatives of homeowners associations, lawyers, and activists. They may review bills, participate in complaint reviews, and refer materials to the courts or police in cases of fraud. However, experts stress that without legislative support these are mostly advisory rather than effective. Citizens’ role and defense mechanismsConsumers have several legal means of influencing providers. They may send written or electronic requests, demand inspections and complaint acts, and, in case of inaction, appeal to local authorities or the State Consumer Service. If the provider does not rectify violations within the set time, citizens may challenge the situation in court or seek compensation. Lawyers advise documenting all violations, keeping photos or videos, copies of requests, and responses. This not only strengthens consumer positions but helps lawyers establish precedent for future cases. Systemic consequencesInspections revealed another trend—regional inequalities in service quality. In big cities, utility oversight is rising, while in smaller communities, shortcomings are left unchecked, often because local officials directly influence communal companies or head their supervisory boards. Additionally, inspections recorded energy manipulation—reporting lower expenses while charging higher tariffs, sometimes leading to resource embezzlement. In 2025, over 90 criminal cases were opened against utility employees at various levels. ConclusionsUkraine’s utility sector needs not only oversight but a major overhaul. Boosting transparency, creating electronic complaint and financial record systems, and mandatory public audits should be core reform elements. For now, the system is fragmented and consumers remain nearly unprotected. State inspections in 2025 showed even major centralization and technological solutions won’t yield results without proper managerial responsibility. The next step is the government’s plan to amend the “On Housing and Utilities” Law, making annual national audits and open-data publication mandatory for companies. Only then is real consumer trust possible, with a fair balance between tariffs, quality, and accountability in utility services. Svitlana Krutorohova — attorney at WINNER Law Firm.If you have questions or concerns about challenging the quality of utility services, defending your consumer rights, recovering losses from poor service, preparing complaint acts, or submitting appeals to regulators or the courts, contact our legal team. Solid legal support from WINNER Law Firm will help minimize risks, secure real compensation, and build an effective legal position in dealings with utility service providers. https://youtu.be/rEd6me-Ume4?si=txR-Ymr3Prhx8ajU

One of the most controversial topics in Ukrainian tax compliance in recent years is the artificial registration of employees as sole proprietors (FOPs). For many companies, this appeared to be a legal way to optimize tax burdens, but the tax authorities have increasingly reclassified such arrangements as employment relations, imposing million-hryvnia fines. In 2025, this practice will remain a priority for the fiscal authorities. The essence of the “employee = sole proprietor” schemeThis scheme is based on substituting official employment (with wages and taxes — USC, PIT, military levy) by signing a civil law contract and registering the worker as an FOP. As a result, the employer saves up to 40–45% of payroll tax, while the “FOP-employee” pays only the single tax (5% of income or 3%+VAT) and minimum USC. At first glance, both sides win: businesses cut their tax burden, and workers receive “net” money. But for the state, this leads to direct tax losses and social insurance payment shortfalls. That is why this scheme is officially designated one of the “risky” models that tax authorities systematically track. How the tax authorities spot disguised employmentThe tax office looks not only at formal contracts, but at the actual substance of relations. It especially focuses on signals typical of employment: subordination to internal company rules; fixed working schedule and office location; use of corporate email, equipment, and internal tools; regular monthly payments of equal sums; lack of entrepreneurial risk or other clients; management of processes by a company manager. If even a few of these are confirmed during an audit or bank inquiry, tax authorities can prove the existence of employment relations. In this case, the company is deemed the legal employer, obliged to pay back taxes — PIT (18%), military levy (5% since 2025), and USC (22%) for the past three years. Sanctions for companies and “FOP-employees”The tax service has the right to apply a suite of financial and administrative penalties: back taxes unpaid for up to three years; a fine of ten minimum monthly wages for each undeclared worker (over 100,000 UAH); no way to avoid USC charges even for closed FOPs; compensation owed to the government budget and the pension fund. Such cases are already being adjudicated, and the tax office increasingly wins. The key position is that a “service contract” does not eliminate the signs of employment if the worker is, in fact, functioning like a regular employee. “Separation of Functions” principle: how to avoid troubleLawyers recommend firms that honestly cooperate with FOPs always follow the separation-of-functions principle: Allow the contractor to choose how and when work is performed; contracts should not describe working time or location. Stipulate the FOP’s own risk and responsibility; the contract should clarify independent provision of equipment or materials. Clearly define the subject; it must be a service or result, not a “position” or “employee function.” Payment must be linked to outcome; regular fixed payments are treated as wages. Ensure the FOP has other clients. Exclusive cooperation with a single company greatly increases requalification risk. Who will be checked firstAfter the moratorium on inspections was lifted in 2025, several risk groups were targeted: companies with large FOP teams using the simplified tax system; IT, consulting, and marketing agencies where “FOP-employees” are over 70% of workforce; firms making regular payroll-like payments to the same FOP accounts; businesses with court cases or tax queries regarding employment relations; risky or tax-evading contractors. The IT sector, which widely uses the “contractor agreement” model, is particularly under scrutiny. Tax authorities now actively analyze payment structures and income sources, especially if FOPs have no other clients. Legislation change and European trendsIn 2025, Ukraine moves towards EU labor norms. The European Commission defines “fake self-employment,” roughly equivalent to Ukrainian standards. Platforms, freelancing, and start-up models are under special attention. The Ministry of Economy and Ministry of Social Policy are preparing a draft law on “economic dependency”—an intermediary status between employment and sole proprietorship. This should reduce pressure on small businesses while protecting the rights of actual FOPs within companies. Court practiceThe courts are increasingly ruling for the tax service when subordination is clear. In precedents from 2023–2025, labor relations between companies and FOPs were established where: fixed schedule and outcome control exists; long-term cooperation with no opt-out; use of corporate communication and tools; payments twice a month in fixed amounts. Positive verdicts for businesses also occur if the firm proves the existence of genuine contracts for clear project deliverables, with no control over working hours. Business impactThe “employee = FOP” model is a direct response to the high tax burden on official payrolls. In the real sector, payroll tax exceeds 40%, pushing companies towards workarounds. The state is increasing not just business inspections, but also oversight of banks, which must report regular transactions between business entities. In 2026, an automated risk-analysis system is anticipated to spot pseudo-FOPs, similar to the VAT invoice blocking model. The aim is not to kill entrepreneurship but to balance the tax load between real businesses and “gray” payroll schemes. ConclusionsThe “employee = FOP” formula has long been one of the most common optimization models. In 2025, the tax service makes it target number one in audit programs, taking any sign of subordination as proof of employment. The trend is clear: the state wants transparent, unified rules—entrepreneurship should mean independence, not just tax minimization. For business, the priorities now are transparent contracts, legally justified FOP relations, and real compliance standards—or tax authorities may treat ordinary contracts as a basis for million-hryvnia assessments. Yulia Popadyn — attorney at tax and customs, “Winner” Law Firm. For questions about tax inspections, payment optimization, FOP contract structure or legal defense in employment and business disputes, contact the attorneys and tax experts of “Winner” Law Firm. Sound legal advice and timely contract audits are the keys to secure business in today’s tax environment. https://youtu.be/rEd6me-Ume4?si=txR-Ymr3Prhx8ajU

In 2025, sole proprietors (FOPs) are once again under strict scrutiny from the tax authorities. After the moratorium on inspections was lifted, the government has resumed active control over small businesses, citing budget deficits and an increase in “shadow” transactions. Lawyers warn: some entrepreneurs will receive inquiries or summonses in coming months, as inspection plans have already been approved and published by the State Tax Service.Who will be inspected firstAccording to lawyers and financial consultants, there are four main groups of FOPs under the tax authority’s spotlight: FOPs with large turnover but without supporting documents. The tax service tracks discrepancies between transaction volumes and declared income. FOPs actively operating through bank accounts but submitting minimal tax declarations are considered risky. Entrepreneurs working in “high-risk” sectors. These include trade in food products, alcohol, tobacco, household appliances, as well as e-commerce, gambling, and currency exchange businesses. According to lawyers, these fields appear most frequently in current inspection schedules. FOPs with hired employees who under-report official wages. New requirements since October 2025 force entrepreneurs licensed for excisable goods to pay two minimum wages (16,000 UAH) or double the social security contributions if no employees are hired. FOPs with a history of amended declarations and sharp fluctuations in indicators. Frequent reporting changes, “negative profits,” delays in paying social security or the unified tax automatically increase the likelihood of inspection.What will be inspectedLawyers note the State Tax Service focuses during inspections on: proper financial record-keeping; consistency between cash flow and declared income; availability of supporting documents (contracts, acts, invoices, receipts); HR policy — official employment and wage level; use of cash registers or software-based registers for cash transactions; tax history and previous violations.Lawyers add that inspectors now have access to bank transactions and can analyze money movements on personal accounts. If regular transfers come from legal entities or various individuals that are not reported in tax filings, the inspection risk increases multifold.Main risks for entrepreneurs Additional tax charges and fines, which may reach hundreds of thousands of hryvnias, even for the past three years; Blocking tax invoices, a major issue for VAT-paying FOPs, as it hinders business with contractors; Interference with business operations, as inspectors often request internal documents requiring accountants and legal expertise; Risk of being classified as a “risky taxpayer,” which blocks VAT refunds and triggers further audits even outside scheduled plans.What should be done nowExperts advise FOPs to conduct internal audits and check the following: tax and social security reports — timely and complete submission; correct business activity codes to avoid exceeding group limits; usage of cash registers or software-based registers — keep all fiscal receipts and customer databases; compliance with turnover limits, especially for the second and third tax groups; proper maintenance of income books, even if simplified; employment contracts for all hired staff.Lawyers recommend avoiding business with companies considered “gray” or temporarily blocked by the tax service, even if partnership seems safe.Actions during inspectionLawyers recommend FOPs follow these rules: demand presentation of official inspection orders and inspector IDs; make copies of acts and comments immediately on the spot; never hand over original documents without a written record; include a lawyer or accountant at all stages of communication with inspectors; document all inspector actions (e.g., on video).Most inspections last 10–15 days but may be extended if violations or suspicious transactions are found.Possible consequences of inspectionIf violations are detected, the tax service may: assess additional taxes, fines, and penalties—up to 50% of the violations’ total sum; initiate inspections of contractors; record the FOP in the “risky taxpayer” system; forward materials to financial monitoring or law enforcement (if evasion or money laundering is suspected).However, lawyers stress: even after an inspection report is filed, a FOP can appeal administratively or go to court. Practice in 2024–2025 shows that courts often rule in taxpayers’ favor if the State Tax Service exceeds its authority or breaches procedures. ConclusionIn coming months, the tax authorities will focus on inspecting risk-prone FOPs: entrepreneurs with high turnover, undeclared employees, excisable goods, or inconsistencies in accounting data. The focus is on transparent cash flow, fiscal discipline, and income confirmation. To minimize risks, lawyers recommend preparing documents, stabilizing accounting, and not postponing tax consultations. For business in 2025, “inspection readiness” is effectively a new survival standard. Yulia Popadyn – tax and customs law attorney at the Law Firm “WINNER”. If you have any questions or issues related to tax inspections, document preparation for the State Tax Service, business protection during audits, tax reporting optimization or appealing decisions of regulatory authorities — contact our legal team for professional advice. https://youtu.be/rEd6me-Ume4?si=BwuKSp_nD0ZAqsh_

Maintaining inventory records for individual entrepreneurs (FOPs) has become one of the key issues of tax control in 2025, with the tax authority regularly reminding about the main rules and sanctions for non-compliance. Who is required to keep inventory recordsInventory accounting is a requirement for FOPs who conduct cash or non-cash transactions when selling goods in the areas of trade, public catering, and service provision. The mandatory category includes: FOPs on the general tax regime; FOPs on the single tax (group 3) who are also VAT payers; FOPs selling technically complex household goods, medicines, medical devices, jewelry and household products made of precious metals and stones, regardless of the taxation regime. Legislative framework and main actsThe regulation of inventory accounting is based on Law No. 265/95-VR and Ministry of Finance Order No. 496 dated 03.09.2021, which sets forth the procedure for FOP accounting. This requirement applies to those who carry out settlements using cash registers (RRO, PRRO). What is included in inventoryInventory refers to the totality of goods that FOPs sell or use for the provision of services. Goods not intended for sale are excluded from accounting: raw materials, production materials, products for own use, and so on. How to keep inventory recordsInventory is kept in a special Inventory Form, which can be maintained either on paper or electronically. The Form must reflect all transactions relating to the receipt and withdrawal of goods, transfers between warehouses or retail outlets, as well as write-offs and returns. Documents confirming accounting: invoices for receipt of goods; write-off acts; receipts, payment documents, invoices; documents for internal transfers. Key details in Inventory FormsThe Form must indicate: entry sequence number; date of information entry; primary document details; total value of goods upon receipt and withdrawal; notes on transfers, write-offs, returns, etc. Accounting at several retail locationsIf the FOP operates in several points of sale, inventory records must be kept separately for each location, clearly indicating the movement of goods between warehouses, sites, etc. Responsibility and sanctionsAbsence of records, improper completion, or neglect of the requirements of Order No. 496 entails fines under the Tax Code of Ukraine. During a tax audit, the FOP is obliged to provide the inventory form and all supporting documents—their absence is considered a breach of business conduct and may result in financial sanctions, orders for correction, blocking registration of RRO/PRRO or suspension of activity. Practical tips and action algorithm Assess whether you are required to keep records—depending on the tax regime, goods category, and transaction method. Choose a form of record-keeping—paper or electronic—but comply with approved requirements as to form details and record structure. Store all primary documents for each operation. Document the movement of goods between points of sale and warehouses with mandatory documentary support. During inspections—provide a complete set of documents upon request of the tax authority. Conclusions and risksMaintaining inventory records is not just a bureaucratic requirement but a tool to protect business against the risks of tax disputes, fines, and financial losses. Systematic work with documentation helps to prevent conflicts with regulatory authorities, optimize inventory management, and reduce costs. Particular attention should be paid to updating form details, clarifying instructions to employees, automating processes, and careful document storage at the place of sale. Yulia Popadyn – tax and customs law attorney at the Law Firm “WINNER”.If you have any questions or issues related to accounting, taxation, settlements with suppliers, or compliance with new FOP inventory legislation requirements, contact the tax lawyer of the Legal Company “WINNER” for professional advice. https://youtu.be/rEd6me-Ume4?si=BwuKSp_nD0ZAqsh_

In autumn 2025, Ukraine fully launched its system against mass advertising calls: citizens will no longer receive intrusive spam calls thanks to new rules adopted by the Cabinet of Ministers and the Ministry of Digital Transformation. The reform responded to years of complaints from Ukrainians inundated with unacceptable volumes of calls offering loans, insurance, marketing, and even fraudulent schemes.Essence of the new rules and their mechanismGovernment Resolution No. 761, enacted on October 2, 2025, for the first time gave mobile operators — Vodafone, Kyivstar, Lifecell — authority to automatically block numbers making mass advertising calls without subscriber consent. All unwanted calls from unknown companies without a contract or permission for communication are considered spam.Spam call criteriaOperators check numbers based on a range of criteria: calls made without live communication (voicemail or recording); average call duration is under 60 seconds over the past 7 days; over 50% of calls go to different, unrelated numbers; the number cannot be called back; high volume of complaints from subscribers; less than 5% of calls from the number result in long conversations; number not listed in company registry or used only for calls—not SMS or internet. How subscribers should actEvery citizen can personally report a spam call—simply use the mobile operator’s app or hotline:Vodafone — 111 / 0-800-400-111 (+38 050 400 111 in roaming);Kyivstar — 466 / 0-800-300-466 (or 105466# in roaming);Lifecell — 5433 / 0-800-20-5433 (+38 063 5433 111 in roaming).Also, you may contact the National Commission for Electronic Communications Regulation or the government hotline (1545), submitting an online request.Effect and first results of the reformWithin weeks of enforcement, thousands of spam numbers have been blocked, and complaints about intrusive calls have sharply decreased. The advertising and call market is being transformed—now marketing campaigns require explicit consumer consent and compliance with new ethical standards.Legal basis and application featuresResolution No. 761 is the first legal framework that both delegates blocking powers to operators and specifies action algorithms: companies calling clients must contract with the operator, registering official contact numbers; every call from an unauthorized number is automatically blocked as spam; vulnerable subscribers from active combat zones received privileges: their numbers won’t be blocked for unpaid services, and SIM cards won’t be canceled. Assisting fraud protectionThe new system minimizes phone scams by eliminating anonymous calls with spoofed numbers. Digital filtering features safeguard Ukrainians against schemes like “your son is at the police station,” “card blocked,” and prevent data leakage in mass calling.Risks and debateInitial critics highlighted possible abuses—risk of unjustified blocking of “legitimate” entrepreneurs or small businesses reaching out to clients from unofficial numbers. The Ministry of Digital and operators promised transparency, prompt dispute resolution, and quick unblocking in case of legal errors.Outlook for the phone advertising marketRemoval of spam calls will evidently transform telemarketing: companies must invest in legal channels—SMS, email, social media; business legal teams will strengthen controls over client database automation and advertising distribution; demand for consulting in communications law and remote advertising ethics will rise. ConclusionBlocking spam calls became a reality through new laws, operator technical integration, and rising digital literacy. Ukrainians receive an effective tool to combat unwanted calls, while business gains clear rules for transparent, safe, and ethical mobile advertising. Advancement of these standards and trust mechanisms between subscribers and companies will shape a new comfort level in digital Ukrainian communications.Svitlana Krutorohova — attorney, Law Firm “WINNER”.If you have questions or issues related to spam calls, protection of personal data, or legal handling of complaints, we recommend contacting relevant attorneys at the Law Firm “WINNER”. https://youtu.be/k2-1dq7hxcY?si=FJCAbWRHbbuoisLf

Restrictions on civil servant salaries in Ukraine are one of the most discussed anti-crisis initiatives of autumn 2025, actively debated in society, expert circles, and parliament.Essence of the legislative initiativeIn September–October 2025, members of parliament, including Finance Committee Chair Danylo Hetmantsev and Speaker Ruslan Stefanchuk, proposed to cap state employee salaries at 80,000 UAH per month. The limit would apply not only to central offices, but also to regional agencies and structural government departments. Exceptions are made for positions related to national security and defense—military and defense sector specialists are not subject to the new rules.Supporters’ reasons and argumentsThe main motivation—fair allocation of public resources during wartime. Deputies argue that the government apparatus should be fiscally responsible and spend moderately when most citizens face income reductions and greater tax burdens. Hetmantsev has repeatedly compared civil servant salaries to those of educators, physicians, and military, highlighting that current salaries in central government exceed the national average by 3–5 times, and pensions by tenfold or more.In addition to budgetary savings, proponents emphasize greater social justice, reduced inequality between officials and citizens, and incentives for improved efficiency in state administration.Education, labor market, and competencePrime Minister Yulia Svyrydenko supported the concept of adequate pay for qualified experts, stressing: to attract and retain professionals, salaries must not be demotivating. Restrictions should be temporary and not undermine the public sector’s competitiveness versus private entities, especially in areas critical for national functionality.Expert assessment, critics’ argumentsIn October, think tanks such as CASE Ukraine, the Institute for Socio-Economic Transformation, and the Center for Economic Strategy opposed the cap and submitted appeals to parliament. Critics’ arguments: savings amount to just 1% of the budget; reduced motivation for skilled state managers, especially in strategic planning and management; risk of losing talent due to “brain drain” to business, international organizations, or the private sector; unresolved salary issues for heads of state-owned enterprises and banks, whose incomes far exceed the proposed limit. Social effect and public expectationsPublic opinions on salary caps vary: many support the initiative as a solidarity measure in wartime, especially given heavy social burdens and inflation. Others expect consistent policy—limits for all, linked to job effectiveness, transparency of financial reporting, and officials’ performance; there are separate concerns about bonuses, allowances, and “hidden” incentives for executives and advisors.International experienceMany countries, especially in crisis periods, set temporary caps on public sector pay. For instance, EU states implement premium payment ceilings, and in the USA, bonus restrictions apply to entities receiving state aid. The effectiveness of such measures depends on transparency, independent oversight, and professional motivation.Key risks for governmentLoss of highly qualified talent in areas where private sector pay far exceeds government levels.Reduced competition for government roles among young and educated specialists.Persistence of shadow incentive schemes that circumvent strict regulation.Redistribution of workloads within the public apparatus, potentially affecting the performance of key agencies.Current status and adoption prospectsThe initiative is currently under parliamentary debate alongside the 2026 draft state budget. The final decision rests with MPs: measures may be adopted in autumn after review of macroeconomic indicators and assessment of impact on government operations. The tension of debate remains.Salary caps for officials are a test of equity, effectiveness, and policy resilience to contemporary challenges. Results will determine the balance between public expectations, professional needs in the state sector, and the fiscal realities of wartime budgeting.Author: Ihor Yas’ko, managing partner, Law Firm “WINNER”, PhD (Law).If you have questions or issues regarding job classifications, taxation of income, or preparing analytical reviews of new anti-crisis limits for the public sector—contact our legal experts for professional advice. https://youtu.be/rEd6me-Ume4?si=l0e5Vg6uhzIMtccR

Limitation periods for audits during martial law in Ukraine have become one of the most pressing issues for business and legal practice in 2022–2025: administration mechanisms have changed, supervisory authorities’ rights were extended, and the restoration dynamics affect entrepreneurs’ and taxpayers’ risks, as well as the ability to protect interests in case of disputes.General rule for limitation periods for auditsBefore the introduction of quarantine and wartime restrictions, according to Article 102 of the Tax Code, the standard limitation period for tax audits and additional tax assessments was limited to 1095 days (3 years) from the deadline for submitting a declaration or paying tax for a specific period. For some cases (transfer pricing), this period extends to 2555 days.Suspension of limitation periods during quarantine and martial lawSince the onset of COVID-19 and subsequently with the start of martial law in February 2022, the limitation period countdown was legislatively suspended — the 1095-day period was effectively frozen. This meant that tax authorities gained the right to audit periods that under normal circumstances would already have expired. A similar situation occurred during quarantine, and since March 2022 — under martial law. Law No. 2260-IX of 12.05.2022 detailed tax reliefs and the mechanism for suspension of audit periods.Moratorium and exceptionsA moratorium was imposed on most tax audits: documentary and factual audits did not commence, and ongoing audits were suspended. Exceptions applied to certain categories of transactions: for instance, if the audit was necessary for budgetary VAT refunds or related to national security and anti-corruption investigations—the audits continued.Mechanism for resumption of periodsUnder current law, limitation periods resume after the end of quarantine or martial law, but for different categories of taxpayers, the recovery period varied. For example:For individual entrepreneurs under the 1–2nd simplified tax group — periods resumed on 1 December 2024.For legal entities and taxpayers under the 3rd group — on 1 December 2023.Thus, the tax authority can audit activities dating back to 2020 or 2021 depending on taxpayer category. Each year, the available audit period narrows—by 2027 the cycle will return to the usual 3 years.Suspension of periods through court procedureThe limitation period countdown also stops via a court decision or in cases where supervising authorities are legally prohibited from conducting audits (paragraph 102.3.2 of the Tax Code). Such suspension can be general (for all taxpayers) or individual—for a specific subject’s application.Practical implications for businessThere is now a risk that supervising authorities may audit large document volumes for past tax periods that under normal conditions would have “closed” due to expiry.Businesses must ensure prolonged storage of accounting, original and payment documents, even if more than 3 years have passed since the reporting period ended.The number of disputes and court proceedings over proper limitation period calculation and resumption has increased.Prospects for resuming standard periodsAccording to the latest changes (fall 2025), the limitation periods for claims have resumed as of September 2025, signaling a gradual return to the normal audit regime for most business types. The moratorium on planned tax audits will also be gradually lifted, and periods for audits normalized.ConclusionLimitation periods for audits during martial law have been greatly extended due to suspension and resumption under special laws. This creates additional risks for businesses, which can be minimized through diligent recordkeeping, regular audits, and legal preparation. Gradual normalization in 2025–2027 will restore the usual regime, but retrospective audits will remain possible for many periods covered by the moratorium and suspension. Oleksandr Nakonechnyi – attorney, head of corporate and commercial law practice at the law firm “WINNER”.If you have questions or issues related to audit limitation periods, legislative changes regarding moratoriums, protection of business interests in tax disputes, or preparing the required documentation during special legal regimes, please contact our qualified legal experts. https://youtu.be/rEd6me-Ume4?si=hsiaxz7BKeFMhfOu

Responsibility of sellers and manufacturers for violations of consumer rights is a key component of fair and safe market relations in Ukraine. Legislation provides a comprehensive mechanism for product and service quality control, protection of citizens’ rights, and establishes effective sanctions for businesses that fail to comply with the law. Systematic efforts by regulatory authorities, ongoing legal reforms, and enhanced judicial practice have led to a new level of consumer protection in Ukraine in 2024–2025. Legal basis of responsibilityThe main regulatory act in this area is the Law of Ukraine “On Consumer Protection” and a range of technical regulations specifying safety and quality requirements for goods, as well as the legal status and powers of regulatory bodies. The law details consumer rights (to information, quality, safety, guarantee, compensation for damages, judicial protection), and sets out clear obligations for producers and sellers: proper labeling, receipts, quality certification, provision of guarantees, refunds or product exchange. Types of legal liabilityViolation of consumer rights triggers these types of responsibility: Administrative: Restricting or refusing realization of consumer rights is punishable by fines up to 500 tax-free minimum incomes, and separate fines for other infractions such as service refusal or lack of product information. Trade personnel bear individual liability. Business sanctions: Manufacture or sale of unsafe, low-quality or undeclared products results in a fine of 300% of the batch value, as well as for lack of required or truthful information. Civil and commercial: Seller or manufacturer must refund money, replace goods, compensate direct losses or lost profit to consumers, and provide product servicing and defect removal at their own expense. Judicial: Consumers are exempt from paying court fees when seeking to enforce rights. The burden of proof is legally on the seller or manufacturer to show absence of fault for product defects. Special liability mechanismsSpecific breaches—improper labeling, lacking quality confirmation, sale of counterfeit or prohibited goods—trigger serious sanctions such as product recall, license revocation, or temporary suspension. When violations cause harm to health or life, criminal law may apply to the seller or manufacturer. Procedure and the role of Consumer Protection ServiceThe State Consumer Protection Service can conduct inspections, purchase control samples, monitor certification requirements, and impose fines or bans. In 2025, special focus is placed on sectoral inspections, sensitive product categories, children’s goods and medical devices. Oversight of e-commerce is strengthened: sellers must register and provide buyers with full information, including guarantees and company details. Service provision without queues, electronic document flows, and online complaints—these changes simplify consumer defense and build trust. Guarantees and examinationsWarranty period is typically two years for new goods and one for used. If a defect arises within the period, the seller must arrange examination at their own expense and, if manufacturer fault is confirmed, fulfill legal demands: refund, replace, or remedy within a reasonable time. Expert examination in disputes protects both sides. Liability and e-commerceRecent reforms increase liability for online sellers: companies must be registered in an official registry and provide confirmation of payment and warranties; sale of uncertified or counterfeit items results in immediate account blocking and heavy fines. Judicial practiceIn recent years, judicial and regulatory complaints have increased, showing the growth of legal culture among consumers. Courts are increasingly siding with citizens, even awarding compensation for moral harm, poor service, or lack of information. In serious product defects, the seller must prove the defect was caused by the customer and not by the company. Reforms and modern trendsIn 2025, transparency standards were enhanced, barrier-free access introduced for vulnerable groups, and greater personal responsibility is expected from retail or service staff. Public awareness campaigns target coercive sales, unfriendly conduct, and manipulative commercial practices. ConclusionsSellers’ and manufacturers’ liability includes a broad range of financial and administrative sanctions and non-judicial measures, damage compensation, strict service and warranty requirements, information disclosure and quality assurance, and active dialogue with regulators and courts. Current best practices foster responsible business and provide consumers tools for effective rights protection. Yuliia Popadyn – Attorney, Tax and Customs Law Practice, WINNER Law Firm.If you have questions or issues with consumer protection, compensation for poor-quality goods or services, or need to challenge a seller’s or manufacturer’s actions, contact our experts.Timely legal support helps determine the best way to restore rights, minimize risks, and protect your interests in today’s market environment. https://youtu.be/rEd6me-Ume4?si=hsiaxz7BKeFMhfOu

In modern Ukrainian business practice, the issue of taxation of erroneously received and returned funds is of special significance. The evolving regulation of tax invoices for such operations requires both deep understanding of legislative innovations by entrepreneurs and accountants, and the ability to respond promptly to practical challenges. The relevance of this issue is driven by the growing number of electronic transactions, including mistaken transfers, and the strict position of tax authorities regarding VAT accounting for such transactions.Legislative grounds for issuing VAT invoices for mistaken fundsAccording to the Tax Code of Ukraine (TCU), a tax invoice must be issued for each full or partial supply of goods and services, as well as for any amounts credited to the bank account as advance payment (prepayment). However, not every transaction in the account results in VAT obligations: everything depends on the existence or absence of business relations between the parties.Mistaken funds without contractual relationsIf a company receives money into its account from a third party with whom no contractual relations exist, according to the State Tax Service position, there is no VAT taxable event and no tax invoice is issued. If the amount is returned to the sender within a certain period (usually 3-5 days), the company is not required to prepare a tax invoice or an adjustment calculation for it.Mistaken funds with a contract in placeA different situation occurs if the company receives an erroneous payment from a counterparty with whom it has business relations (for example, payment exceeding the invoice amount or payment made by multiple persons at once). In this case, the amount is treated as an advance for future supplies. On the date of receiving the funds, the company must determine VAT liabilities, issue, and register a tax invoice for the entire amount. If a portion is later recognized as mistaken and returned, an adjustment calculation is made to reduce the VAT liabilities after its registration in the Unified Register of Tax Invoices.Practical algorithm for accountants Analyze the purpose of received funds: Determining the presence or absence of contractual relations with the payer is key for further actions. Issuing the tax invoice: If a contract exists, the invoice is issued for the total amount, regardless of whether part of it is “mistaken”. Processing the adjustment calculation: Refunds are documented by a separate adjustment calculation, registered in the Unified Register. Submitting explanations to the tax service: In complex cases, if additional information is requested (discrepancy inquiry or VAT invoice suspension), an explanation of the transaction details is provided.Judicial and fiscal practiceThe State Tax Service of Ukraine has repeatedly confirmed that where no goods or services were to be provided for the received funds (no contract/invoice), no tax invoice is issued and the amount is excluded from VAT taxation. Additionally, if a tax invoice is mistakenly issued, it should be later annulled. However, if contractual relations exist, a VAT invoice is required — even if the refund occurs the same day.Tax consequences of refundsIn typical cases, when an erroneously paid amount is refunded, VAT liability exists only for the amount remaining in the company account as the actual payment for supply. If everything is returned, VAT obligations are zeroed out, but this is recorded only after the adjustment calculation is registered. Not including a mistaken invoice in the VAT declaration is also legally justified, as no actual supply occurred and there is no tax base.Typical problems and risksBlocked tax invoices — due to the formal approach of the tax service.Time losses on preparing explanations and supporting documentation.Ambiguous interpretations of funds status in complex settlements or overpayments.Lack of uniform practice in different regions or among tax inspectors.Risk of a tax dispute due to late notification about a refund.Recommendations for businessDocument all counterparty refund requests (official letters, email).Promptly verify the purpose of all payments.In doubtful situations, submit explanations to the tax authorities to avoid VAT invoice registration issues or declaration discrepancies.ConclusionsIssuing VAT invoices for mistaken and refunded funds remains one of the most sensitive aspects of VAT accounting, requiring careful analysis of each transaction with regard to contractual basis, supporting documents, and the current tax authority position. Adhering to transparent procedures and promptly interacting with fiscal authorities reduces financial and penalty risks for enterprises and protects them from future tax disputes. Author: Maksym Bahniuk, Head of Tax and Customs Law Practice at WINNER Law Firm.If you have any questions or issues related to the return or crediting of erroneously received payments, preparation of tax invoices and adjustment calculations, or tax dispute resolution, seek professional advice from our company’s specialists. Timely response to such situations is the key to your business’s financial security and the avoidance of unnecessary tax risks. https://youtu.be/rEd6me-Ume4?si=l0e5Vg6uhzIMtccR

Hetmantsev has proposed to raise the corporate income tax rate for banks to 50% in 2026—one of the most widely discussed fiscal initiatives this fall, positioned as a key source of state budget revenue amid wartime conditions. Below is a comprehensive analysis of the drivers, details, expectations, and risks of this tax decision for the state, banking sector, and the economy as a whole. Essence of the InitiativeDraft Law No. 14097 provides for a temporary (only for 2026) increase in the corporate income tax rate for banks to 50% from the current 25%. Additionally, it proposes to prohibit the use of loss carryforwards when calculating tax liability. With this, the state expects to raise about UAH 30 billion in extra revenue to cover critical budget expenditures under martial law. Logic of the Bill’s AuthorAccording to Danylo Hetmantsev, head of the VR Committee on Finance, this initiative is an exceptional and compelled response to unprecedented fiscal challenges and the need for sustainable defense funding. Hetmantsev noted that the banking sector has posted record profits in recent years, even as the effective tax rate dropped—from 8.1% in 2024 to 7.4% in 2025. The state has already used extraordinary measures to raise rates for banks in 2023–2024, but intends to keep the base rate in 2025 and is pre-announcing the hike for 2026. Budget ImpactThe main aim is to boost the state budget by UAH 30 billion owing to record sectoral profits, which is a critical source during war. A substantial share of these revenues will be used for defense, social programs, and macroeconomic stabilization. The imperative to replenish the budget was the main argument in choosing banks for additional taxation. Predictability and Limits of the InitiativeUnlike in previous years, the increased rate is not being imposed retroactively, and is being announced in advance—giving banks time to adjust business models and update planning. According to Hetmantsev, predictable tax policy builds business trust by ensuring transparency of fiscal rules. Critics’ ArgumentsImmediately after the announcement, representatives of the banking sector and the financial community voiced several concerns. Major risks include: Excessively high taxation could undermine banks’ motivation to invest in development, and lead to reduced lending and innovation. Outflow of some bank profits abroad, reduction of dividends to shareholders who already face higher risks. Prolonged extraordinary rates might damage the Ukrainian banking sector’s attractiveness to foreign investors, especially given intensifying competition in financial services. State of the Banking SystemUkrainian banks, despite the war, continue to report rising profits due to increased interest income and stabilization actions by the NBU and Cabinet. Yet, some institutions remain loss-making, and profits are unevenly distributed—state-owned and leading market banks generate the bulk of windfall profits. Market and Economic ImpactPotential effects include: Extra budget inflows to cover defense, which is an unconditional priority. In the short term, high-profit banks can adapt to new terms, but in the medium term, lending policies may change—especially for SMEs and low-margin sectors. High rates remain for 2026 only, but removing retroactivity doesn’t exclude the risk of “prolonged” emergency taxes if martial law persists. International ContextOther countries under similar circumstances have used emergency taxation on bank and energy company profits (notably during the pandemic or energy crises). International practice supports such tools in wartime or times of catastrophe, but always emphasizes time limits and decision transparency. Balancing InterestsThe main challenge is balancing fiscal needs with sustaining banks’ incentives for innovation, lending, and servicing the economy. Record sectoral results strengthen the arguments for the policy, but the risks of reduced long-term attractiveness and slowed financial system growth remain. Adoption ProspectsAs of October 2025, the draft law has only been tabled in Parliament; consultations with experts and bankers are ongoing. It will likely spark intense debate. The main arguments in support are the temporary, wartime, critical nature and a potential UAH 30 billion gain for the budget. ConclusionHetmantsev’s 50% tax for banks in 2026 is a classic example of fiscal compromise in wartime—an exceptional, temporary budget measure targeting a sector with windfall profits in difficult times. The real impact will only be clear after the law is adopted, while the question of balancing state interests and stable financial sector growth will remain open for public oversight and expert debate. Author: Ihor Yasko, Managing Partner of WINNER Law Firm, PhD in Law If you have questions or issues regarding bank profits taxation, new legislative initiatives, or need to assess the impact on banking business and financial planning, contact the lawyers and experts at WINNER Law Firm. https://youtu.be/rEd6me-Ume4?si=l0e5Vg6uhzIMtccR