Key issues
- The National Bank of Ukraine has introduced a “borrowing” limit and expanded business opportunities for certain foreign exchange operations.
- Appendix BD to the corporate income tax return
- An electronic primary document with a QES may be signed later than the transaction date.
- Failure to submit SAF-T UA during an audit at the request of the State Tax Service: a penalty under para. 121.2 of the Tax Code of Ukraine
- Change in the legal form of a counterparty during the year: transfer pricing report
- Grounds for imposing a penalty for unreported indicators in the CFC Report
Experts advice
- Recommendations for companies with remote employees in other countries.
- Employment of persons with disabilities under the new rules
Court practice
- Actions of a legal entity’s director exceeding their authority. Risks of contracts being declared invalid.
Key issues
- The five-year deadline for digitizing employment record books is coming to an end.
- Return of previously imported goods: “compensating” VAT liabilities under para. 198.5
- Payment of income “through a holding company” without beneficial owner status: which documents are required to apply the tax treaty
- As of 01.01.2026, security services prohibit legal entities from being taxpayers of Group 3 of the single tax
- Income from discounting long-term liabilities is included in the income of a single-tax legal entity
Experts advice
- The Ministry of Economy has reinstated the salary criteria for recognizing an enterprise as critically important.
Court practice
- Martial law and penalties for non-refund of VAT
Key issues
- Non-operating expenses and the corporate income tax base
- Transfer pricing under a commission agreement (Individual Tax Consultation)
- “Inherited” liabilities in the course of reorganization in the Controlled Transactions Report (Individual Tax Consultation)
- The NBU has introduced another round of currency liberalization measures
Experts advice
- How to ensure timely registration of tax invoices by suppliers
Court practice
- Employment of persons with disabilities and the consequences of errors in reporting
- Transfer pricing: inappropriate sources of information on comparable transactions
Key issues
- Resumption of reporting to the State Statistics Service
- Reinstatement of POS (cash register) penalties
- Date of electronic document creation
- CbC Report for 2024
- Loss of control over a CFC during the reporting year
Experts advice
- Guideline on submitting Form No. 20-OPP
Court practice
- Beneficial ownership status of a non-resident
Key issues
- Procedure for VAT exemption of transactions under international technical assistance (Individual Tax Consultation)
- Ukraine has received its first CbC Reports
- For transfer pricing purposes, a permanent establishment is treated as a non-resident (Individual Tax Consultation)
Experts advice
- Actions of the tax authority within the framework of the pilot project on compliance risks
Court practice
- Exemption from penalties for violations of tax legislation during the period from March 1, 2020 to June 30, 2023
Key issues
- Renewal of the limitation period
- Contribution of real estate by a non-resident to the charter capital of a resident company (Individual Tax Consultation)
- Taxation of transactions with non-residents using “high-risk” legal forms (Individual Tax Consultation)
Experts advice
- Submission of the Country-by-Country Report: key details to consider
Court practice
- Accounting for royalty expenses and advertising videos
- Grounds for liability for late fulfillment of tax obligations
Key issues
- Renewal of the Limitation Period: Draft Law Adopted
- Export Security Regime: New Clarifications
- Debt Forgiveness: Tax Authorities Insist on Two Adjustments
Experts advice
- Specific Focus Areas in the Context of Transfer Pricing Audits
- Violation of Deadlines for Imposing Sanctions for Failure to Meet the Disability Employment Quota. Advantages for Employer Protection
Court practice
- When the Court May Reduce the Amount of Penalties
Key issues
- Charitable adjustment of financial results: changes to the Tax Code
- Free export: when to apply Article 198.5 of the Tax Code
- Significant changes to the Law on Accounting: draft of the Ministry of Finance
Experts advice
- Importation of imported goods
- Calculation of the share of unreceived funds: issues of RES
- Abolition of the Commercial Code: what changes will occur in the activities of legal entities
Court practice
- Review of the case law of the CAS of the Supreme Court for 2024
- Application of the comparative uncontrolled price method
Key issues
- Blocked RK: countdown to the deadline for submitting documents
- Dividends in one reporting period, advance payment in another: Reporting
- TTN and recognition of costs for motor transport services
Experts advice
- Fast court procedures for collecting small monetary debts
Court practice
- Collecting funds from a debtor enterprise that is in a state of liquidation is an effective way of protection
Key issues
- List of countries for TC purposes: update from the Ministry of Finance
- Part-time workers have the right to sick leave: President signs law
- The PN was drawn up at the beginning of martial law and is not included in the declaration
Experts advice
- Blocked tax invoices: nuances of PC display
Court practice
- Supreme Court: the wording “for each day of delay” and the term of the penalty