CRS is becoming more detailed. What will the State Tax Service be able to see about your foreign assets from 2027?

Ukraine is transitioning to the updated standard for the automatic exchange of financial account information — CRS 2.0.

From 2027, international information exchange will become more detailed.

What does this mean for owners of foreign accounts, companies, and international structures?

Under the CRS rules, financial institutions collect and verify information about:

• the account holder;
• the account holder’s tax residency;
• controlling persons of companies;
• the ownership structure;
• the characteristics of the financial account;
• the account balance or value;
• certain income paid or credited to the account.

CRS 2.0 further strengthens due-diligence procedures and expands the detail of reporting.

Particular attention is paid to persons with multiple tax residencies, controlling persons, and the accuracy of self-certification.

The scope of modern financial instruments is also expanding.

The updated standard includes specified electronic money products and central bank digital currencies.

The changes also affect certain financial products linked to crypto-assets, as well as investment entities that invest in them.

⚖️ Lawyer’s opinion

The key question today is no longer:

“Will the State Tax Service find out that I have an account abroad?”

A far more important question is:

“What exactly will the State Tax Service receive about me, and does that information match what I declare in Ukraine?”

For example, you may:

• be a Ukrainian tax resident;
• own a company abroad;
• control it as a CFC;
• have a company with an account at a foreign bank;
• receive dividends or other income;
• invest part of your funds through foreign financial instruments.

Each of these elements may be entirely lawful when considered separately.

The issue arises when the data do not match.

A bank identifies one tax residency.

A Ukrainian tax return shows a different picture.

You are listed as a controlling person in the structure of a foreign company.

At the same time, the CFC notification or relevant reporting in Ukraine is missing or contains different information.

The ability to cross-check information is becoming one of the main tax risks.

Therefore, owners of international structures should review the entire chain in 2026:

tax residency → foreign account → company → CFC → controlling person → income → Ukrainian tax return.

The source of capital used for investments and transactions involving digital assets should also be reviewed separately.

One important nuance: CRS 2.0 does not mean that the State Tax Service will automatically see every crypto wallet you own.

A separate standard — CARF — exists for the direct international exchange of information on crypto-asset transactions.

However, CRS 2.0 and CARF are moving international financial oversight in the same direction: toward significantly greater transparency of assets and transactions.

It is therefore better to review an international structure before questions arise from the tax authorities.

WINNER Law Firm advises on CRS, CFCs, international taxation, tax residency, and the structuring of foreign assets.

📞 +38 096 574 81 02
📧 info@uk-winner.com

Author: Ihor Yasko, Managing Partner at WINNER Law Firm, PhD in Law.