Should the tax authorities be informed about foreign accounts?

In 2025, the State Tax Service of Ukraine (STSU) received full access to automatic international exchange of tax information regarding the accounts of Ukrainian residents abroad. Thanks to the introduction of the CRS (Common Reporting Standard), Ukrainian tax officers will be able to annually receive reports from foreign financial institutions on fund movements, account balances, and the income of Ukrainians in over 110 jurisdictions worldwide, which radically changes the approach to oversight of foreign assets, combating tax evasion, and automating financial supervision.

CRS: global financial transparency
CRS is a model for annual data exchange between the tax authorities of participating countries, developed by the OECD and implemented in Ukrainian law since 2023. From now on, Ukrainian banks, insurance, investment and other financial institutions automatically report on the accounts and operations of residents (individuals and legal entities) to the STSU; in return, Ukraine has the right to receive equivalent information from abroad.

The first exchanges covered data on accounts with a balance of more than $1 million, both for individuals and companies. The second exchange (September 2025) extended to accounts over $250,000. Accounts with a lower balance, for now—under martial law—are not subject to taxation or financial control, although the information is collected and may be analyzed in the future.

What information is transmitted
Under CRS, the STSU receives the following data:

• full name, identification code, date of birth, address of the account holder;
• account number, name of the financial institution;
• balance at the end of the year or at the date of account closure;
• all receipts and write-offs for the year, dividends, interest, capital gains, or other income;
• information about whether the account is owned by a company or by a nominee (trust, partnership).

How and why the received information is used

• Verification of tax residency: the STSU checks the citizenship status of the owner, compares with declarations and official residence.
• Detection of undeclared income and tax evasion: if the account owner has not declared funds that qualify as income under Ukrainian law, the tax authority may additionally charge taxes, fines, and penalties.
• Control over foreign investments, assets, and business: corporate accounts, passive income accounts, e-wallets, foreign exchanges, and payment systems are becoming transparent for Ukrainian tax authorities.

Consequences for Ukrainians abroad
If an account exceeds $250,000 and is not declared or taxes have not been paid, the STSU has the authority to assess additional tax obligations and fines (especially from 2026 when mass use of received data in audits is expected). Accounts with a lower balance are subject to a “tax silence” regime for now, but the data may be used in the future if martial law status or legislation changes. Transactions via e-wallets, international payment systems, and virtual accounts (PayPal, Revolut, etc.) are subject to analysis.

Unified register of accounts and national control system
Ukraine is developing a Unified State Register of bank accounts and safes for individuals and legal entities, which will be automatically integrated with international CRS reports. Financial agents submit information annually by July 1 to the STSU, and in September a report is sent to CRS—then the Ministry of Finance verifies and analyzes the data.

Legal and tax risks
Opening a foreign account or investing outside Ukraine must now be carefully justified and transparent to the tax authorities. “Forgotten” accounts, undeclared investments, or inherited sums may be grounds for additional tax charges and financial liability—up to criminal prosecution in cases of significant tax evasion.

Practical advice
All Ukrainian residents with a foreign bank account over $250,000 must ensure it is properly recorded in the asset and income declaration. Businesses should consider CRS when structuring their corporate finances and flows. It is best to consult tax/international experts in advance on tax residency, reporting, and optimize tax burden transparently.

Conclusions
The STSU now has a real international tool to control all financial accounts of Ukrainians abroad; from autumn 2025 this control will be comprehensive and systematic. CRS exchange with over 110 countries is a step toward global tax transparency that enables the detection of undeclared income, prevention of tax evasion, and optimization of fiscal policy. All Ukrainians should act transparently, as financial “shadows” are becoming increasingly visible to the tax authorities.

Author — Maksym Bahniuk, Head of Tax and Customs Law Practice at the Law Firm “WINNER”.