The government has approved new rules for taxing assets in accordance with EU standards

The Cabinet of Ministers of Ukraine has approved a draft law submitted by the Ministry of Finance aimed at bringing tax rules into line with European Union standards.

The document provides for the introduction of taxation rules for the transfer of assets outside Ukraine, general mechanisms to combat tax abuse, and provisions to address the effects of hybrid mismatches. The changes were developed in accordance with EU Council Directive 2016/1164 (ATAD).

The registration of the draft law in the Verkhovna Rada is a structural milestone of the EFF program with the International Monetary Fund (IMF).

The document aims to protect the national corporate income tax system from tax evasion, tax base erosion, and the shifting of profits to jurisdictions with lower tax rates. Along with the draft law on the implementation of these provisions.

The agency notes that the draft law provides for the introduction of a mechanism to tax the appreciation in the value of assets (“exit tax”) in the event that assets are transferred outside Ukraine, if the state loses the right to tax them. The rule applies to corporate income tax payers, including non-residents with permanent establishments; however, it does not apply to the temporary (up to 12 months) transfer of assets as part of financing, collateral, or liquidity management transactions, nor to transfers between a taxpayer and a subsidiary if Ukraine does not lose its right to tax such assets.

The document also introduces a general anti-abuse rule (GAAR), under which transactions without valid commercial reasons, carried out for tax benefits in violation of the Tax Code, will not be recognized as abusive. The burden of proof will rest with the tax authority, and audits and the consideration of objections will be carried out by a specially established Commission comprising representatives of the Ministry of Finance and experts from the taxpayer.

Rules are also being introduced to address the consequences of hybrid mismatches, reverse hybrid mismatches, and tax residency mismatches arising from differences in the tax treatment of instruments or entities across different jurisdictions.

The new rules will take effect on the date the law is published and will come into force on January 1, 2028, following its adoption by Parliament. Administration will be carried out within the framework of existing reporting requirements without the introduction of separate tax returns.

The document has not yet been registered with the Verkhovna Rada.

This was reported on the Ministry of Finance’s website on Wednesday.

Since the beginning of the year, Ukraine’s state budget has fallen short by ₴50 billion in revenue, according to Marchenko.

As a reminder, nearly 2 million UAH in penalties for violating the terms of contracts for the supply of goods for defense needs were credited to the state budget. The funds were collected following lawsuits filed by the Bila Tserkva Specialized Prosecutor’s Office for Defense Affairs as part of the “Defense Interest” program.

Members of Parliament submitted 5,236 amendments to the government’s draft state budget of Ukraine for 2027. This is the largest number of amendments in at least the last 24 years.