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Tax & Legal updates (20.10.26)
20 October 2026
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Legal
Tax
The Forvis Mazars team has prepared for you a list of recent Tax & Legal updates in Ukraine.
Below, you will learn about:
- New air raid alert levels: what businesses should do;
- New rules for taxation of postal shipments and e-commerce;
- Ministry of Agrarian Policy updates sector-specific criteria;
- Foreign economic activities for agribusiness: extension of settlement deadlines clarified;
- Compensation for damaged property and war risk insurance expanded;
- NBU raises key policy rate to 16%;
- Cross-border payments: opportunities for Ukrainian businesses expanded;
- Defence City: lease of state and municipal property without an auction.
New air raid alert levels: what businesses should do
Government Resolution No. 1092 dated 4 September 2026 introduced a differentiated approach to responding to air threats.
The Ministry of Internal Affairs (MIA) has also issued practical guidance on the implementation of the new rules and the conditions for the continuation of business operations during an air raid alert.
Key aspects:
- two threat levels have been introduced: red and yellow;
- under a red threat level, operations must be suspended, and employees and visitors must proceed to a shelter;
- based on the current wording of the Resolution and the MIA’s guidance, during a yellow threat level businesses may:
- operate in premises, buildings, structures, or areas where protective structures, temporary or permanent shelters for employees and visitors are available, or in premises, buildings, or structures classified as dual-purpose facilities or containing a designated safe space;
- operate in premises, buildings, structures, or areas where no temporary or permanent shelter is available, subject to agreement with the workforce until a shelter is arranged, but for no longer than three months from the effective date of the Resolution.
- Thus, the above provisions are not fully aligned:
- the first provision allows businesses to operate where a protective structure, a temporary or permanent shelter, a dual-purpose facility, or a building containing a safe space is available;
- whereas the other provision only temporarily permits operations without a shelter, subject to agreement with the workforce.
- Therefore, the requirements for continuing operations during a yellow threat level require further clarification.
- Thus, the above provisions are not fully aligned:
- a new concept of a “safe space” has been introduced. A safe space is the most protected area within a building and must be specifically designated and equipped based on the relevant calculations. At the same time, the procedure for identifying, equipping, and documenting such safe spaces requires the adoption of an additional resolution developed jointly by the MIA and the State Emergency Service of Ukraine, which is currently under consideration by the Government;
- upon the announcement of an air raid alert, a business entity must ensure that employees and visitors are informed of the alert. Visitors may remain in the relevant premises, buildings, structures, or areas at their own discretion.
Source: Government Resolution No. 1092 dated 4 September 2026 “Certain Issues of Optimising the Protection of the Population and Responding to Threats Posed by Air Attack Weapons”; Official guidance issued by the Ministry of Internal Affairs regarding Government Resolution No. 1092 dated 4 September 2026.
New rules for taxation of postal shipments and e-commerce
The Parliament has adopted in the second reading and as a whole Draft Law No. 15460, which aims to align the taxation rules applicable to international postal and express consignments with European Union standards. The draft law forms part of a broader package of reforms intended to modernise the taxation of e-commerce and distance sales of goods in Ukraine.
Key aspects:
- special rules for the assessment and payment of VAT are introduced for distance sales of goods, including specific rules governing the application of exchange rates to such transactions;
- new customs control and declaration requirements are introduced for goods imported through international postal and express consignments;
- the point at which the obligation to pay customs duties arises for goods purchased through electronic platforms is clarified;
- electronic interface operators (marketplaces), their intermediaries, and other designated participants in e-commerce are identified as persons responsible for the payment of customs duties and VAT;
- a special VAT administration regime is introduced for distance sales of goods;
- requirements are established for the registration and record-keeping of non-resident electronic platforms, their intermediaries, and resident e-commerce operators;
- separate rules are introduced for the customs clearance of goods with a total customs value not exceeding EUR 150 that are imported through international postal and express consignments;
- a transitional period is introduced during which postal operators, express carriers, and electronic platforms will be exempt from administrative liability for the late or incomplete payment of VAT in respect of consignments valued at up to EUR 150, provided that the tax is paid in full;
- in practice, this represents a transition to the European model of e-commerce taxation, under which a significant part of the responsibility for the assessment and payment of VAT is assigned to electronic marketplaces and intermediaries, while the control of low-value international consignments becomes more automated.
Ministry of Agrarian Policy updates sector-specific criteria
On 18 October 2026, Order of the Ministry of Agrarian Policy No. 11 dated 2 September 2026 entered into force, approving new criteria for determining enterprises, institutions and organisations that are important for sectors of the national economy within the areas falling under the competence of the Ministry of Agrarian Policy.
Key aspects:
- the minimum area of agricultural land required to meet the criteria has been reduced from 1,000 hectares to 200 hectares;
- the minimum annual net revenue required to meet the criteria has been reduced from UAH 40 million to UAH 20 million.
Foreign economic activities for agribusiness: extension of settlement deadlines clarified
On 3 September 2026, the Government amended the procedure under which the Ministry of Economy issues opinions on the extension of maximum settlement periods under foreign economic contracts for goods classified under certain codes of the Ukrainian Classification of Goods for Foreign Economic Activity (UCGFEA), including certain grain and oilseed crops, vegetable oils, and processed agricultural products.
Key aspects:
- the amendments apply to transactions involving certain types of agricultural products, including grain and oilseed crops, vegetable oils, and certain processed agricultural products;
- eligible foreign economic contracts may be granted an opinion of the Ministry of Economy regarding the extension of the maximum settlement period;
- the settlement period may be extended by no more than 180 days;
- the amendments do not provide for an automatic extension of settlement periods for all exporters but rather for the possibility of extending such periods upon obtaining the relevant opinion of the Ministry of Economy;
- the special rules apply for the duration of martial law.
Compensation for damaged property and war risk insurance expanded
Government Resolution No. 1157 dated 17 September 2026 expanded the list of property eligible for partial compensation and clarified the mechanism for compensation of insurance premiums under war risk insurance contracts. The Resolution entered into force on 22 September 2026, except for certain provisions that will become effective 30 days after its publication.
Key aspects:
- the list of property eligible for compensation has been expanded to include:
- fuel owned by operators of excise warehouses;
- vehicles used for the transportation or storage of fuel;
- agricultural machinery;
- trucks and trailers with a technically permissible maximum mass exceeding 7.5 tonnes.
- compensation has been extended to movable property damaged while in transit through high-risk areas;
- Kyiv and Kyiv Region have been added to the list of high-risk areas;
- the maximum annual compensation of insurance premiums has been increased to UAH 5 million;
- compensation of insurance premiums has been extended to leased property;
- the list of evidence of damage has been clarified and includes documents confirming ownership, an extract from the Unified Register of Pre-Trial Investigations, documents issued by the SES, the police or the Security Service of Ukraine, and damage assessment reports.
NBU raises key policy rate to 16%
By Decision of the Board of the National Bank of Ukraine No. 313-rsh dated 17 September 2026, the key policy rate was increased from 15.5% to 16% per annum.
Source: Official announcement of the National Bank of Ukraine.
Cross-border payments: opportunities for Ukrainian businesses expanded
On 17 September 2026, NBU Resolution No. 105 entered into force, expanding the list of foreign exchange transactions that may be carried out through non-bank payment service providers.
Key aspects:
- Ukrainian legal entities and individual entrepreneurs may receive payments from non-resident individuals for goods, works and services through non-bank payment service providers, with funds credited to hryvnia payment accounts (limit: the equivalent of UAH 200,000 per month);
- such accounts may be credited with the hryvnia equivalent of funds in foreign currency received from abroad through international card payment systems (in particular, SWIFT transfers and transfers through international card systems (such as Visa and Mastercard));
- the amendments apply only to transactions conducted through non-bank payment service providers and do not remove other foreign exchange restrictions applicable to businesses (in particular, the restrictions set out in NBU Resolution No. 18 remain in force).
Defence City: lease of state and municipal property without an auction
On 28 September 2026, amendments entered into force under which the Government expanded the mechanism for transferring property to defence-sector enterprises without an auction.
Key aspects:
- eligibility has been extended to Defence City residents, manufacturers of unmanned systems, electronic warfare equipment and passive technical counter-surveillance systems;
- it is sufficient to satisfy one of the four prescribed criteria, rather than all criteria simultaneously;
- the mechanism now covers not only state-owned property but also municipal property;
- in respect of municipal property, local self-government bodies are recommended to establish annual rent at the level of 8% of the appraised value;
- to obtain property, an enterprise must submit to the lessor a written application requesting inclusion of the relevant asset in the list of property that may be leased without an auction, together with documents confirming compliance with at least one of the prescribed criteria.
Our experts:
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| Denys Shendryk Partner, Head of Tax & Legal Department | Tetiana Levkivska Head of Legal Practice | Karyna Kirova Tax Manager |
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