TAX ALERT 17.09.2026 | Digest of Key Tax News

Introduction of the updated CRS standard

On September 11, 2026, the Ministry of Finance of Ukraine announced Ukraine’s accession to the Addendum to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.

This document expands the list of information subject to automatic exchange between the supervisory authorities of the respective states.

From now on, the Ukrainian tax authorities will receive information, in particular, regarding:

• the existence of a valid self-certification for each financial account holder; 
• the specific role and grounds on which a reportable person is recognised as a controlling person of the legal entity that holds the account, as well as the existence of a valid self-certification for each such controlling person; 
• the type of account, namely: whether it is a preexisting or new account, whether it is a joint account, and the exact number of its co-owners; 
• the role of the person, where they hold a stake in investment entities, on the basis of which they are considered the owner of such a stake.

As stated by the Ministry of Finance of Ukraine, this additional information will be used by the tax authorities, in particular, to identify undeclared foreign income, as well as to combat tax evasion and capital flight abroad.

Abolition of the VAT exemption for goods purchased via digital platforms

Draft law No. 16051 dated September 7, 2026 and an alternative draft law No. 16051-1 dated September 9, 2026, have been registered in parliament. 

Both initiatives concern the abolition of the €150 limit on the total value of goods imported into the customs territory of Ukraine by e-commerce platforms and their intermediaries for recipients who are natural persons, with a view to subjecting such goods to value added tax.

It is proposed that, when carrying out such transactions, suppliers of goods will not claim a tax credit or issue tax invoices in respect of them. 

If the e-commerce platform is a non-resident, the obligation to calculate and pay the relevant tax will fall on the intermediary specified by it.

Alternative draft law No. 16051-1 dated September 9, 2026 also proposes that the value-added tax paid in accordance with the procedure described be channeled towards meeting the needs of the Armed Forces of Ukraine.

On September 16, 2026, parliament adopted the alternative draft law No. 16051-1 dated September 9, 2026 as a basis.

New rules for determining financial results: draft legislation in the parliament

On September 4, 2026, draft law No. 16036 “On Amendments to the Tax Code of Ukraine regarding the implementation of rules to counter tax avoidance practices that have a direct impact on the functioning of the internal market of the European Union and Ukraine, in accordance with Council Directive (EU) 2016/1164 of 12 July 2016 (in respect of the provisions of Article 4 of that Directive)” was registered in the Verkhovna Rada of Ukraine .

We have previously written about this draft law whilst it was being considered by the Ministry of Finance of Ukraine.

It should be noted that the initiative concerns changes to the rules for determining financial results, in particular by introducing a cap on the impact of borrowing costs on the financial results of corporate income tax payers.

The draft law was submitted to parliament with certain amendments regarding the establishment of a safe monetary threshold for the limit on expenses, the rules for accounting for exchange rate differences, as well as reporting requirements and document retention periods. 

Should the relevant law come into force, the updated rules will take effect from January 1, 2028.

Changes to VAT administration rules: draft law

On September 4, 2026, draft law No. 16037 “On Amendments to the Tax Code of Ukraine Regarding the Improvement of Value Added Tax Administration” was registered in the Verkhovna Rada of Ukraine.

We have previously written about this draft law during the public consultation stage. It provides, in particular, for:

• a mechanism for the pre-completion of reporting documents for sole traders;
• a change to a quarterly reporting period for sole traders who are VAT payers;
• updates to the rules for drawing up tax invoices;
• changes regarding certain grounds for conducting unscheduled audits.

The registered draft law has also been supplemented with provisions regarding the conduct, under certain conditions, of unscheduled documentary audits regardless of the amount of the claimed tax refund and/or a negative VAT balance.

This exception will apply to cases where, following a desk audit of a value-added tax return, circumstances are identified which cannot be investigated within the scope of the desk audit and which have affected or could have affected the calculation of the VAT amount claimed for refund and/or the negative VAT balance.

Updates to transfer pricing rules: draft law registered

On September 4 2026, draft law No. 16035 “On Amendments to the Tax Code of Ukraine Regarding the Further Improvement of Transfer Pricing Rules” was registered in the Verkhovna Rada of Ukraine.

We have previously written about this draft bill whilst it was at the public consultation stage. It was subsequently revised and registered with the Verkhovna Rada of Ukraine.

In its revised form, the draft bill currently includes, in particular, the following key changes to the transfer pricing rules:

• the introduction of an updated model for transfer pricing penalties based on a differentiated scale;
• an update to the value criteria for recognising transactions as controlled (in particular, the calculation of the volume of a taxpayer’s business transactions at prices consistent with the “arm’s length” principle); 
• clarifying the algorithm for identifying and determining the actual terms of controlled transactions for the purposes of a comparability analysis; 
• clarifying the application of transfer pricing methods, in particular the resale price, “cost plus”, net profit and profit split methods; 
• refining the concept of analysing transactions involving intangible assets (DEMPE analysis).

If adopted, the relevant law will come into force on January 1, 2028.