GOOD LEGAL SOLUTIONS | LAW FINANCE TAX | GLS |

In April 2025, Ukraine registered Draft Law No. 10168 introducing new tax rules for individuals selling goods or providing services via digital platforms. This legislation aligns with the EU DAC7 Directive and Ukraine’s commitments under its IMF memorandum. The goal is to implement an automatic tax information exchange system and harmonize with EU tax standards.

📌 What Does the Draft Law Include?

The key proposal is to require digital platform operators to report income earned by individuals using their platforms to the State Tax Service of Ukraine (STS). The mechanisms mirror the EU DAC7 framework.

Requirements include:

• verification and identification of platform users;
• annual reporting by platforms to STS;
• disclosure of income volumes, transaction counts, service types, and more.

👥 Who Is Affected?

Individuals operating via over 50 platforms, including OLX, Prom, Booking.com, Bolt, Uber, BlaBlaCar, Etsy, Amazon, Fiverr, Upwork, Glovo, etc.

📦 Types of Activities Covered:

• rental of residential or commercial property;
• sale of goods;
• provision of personal services (e.g., caregiving, repairs, tutoring);
• rental of vehicles.

💰 What Is the Tax Rate?

Two-tier structure proposed:

Preferential rate — 10% (5% PIT + 5% military levy) if all conditions are met:

• use of a special designated bank account;
• not registered as an entrepreneur or self-employed;
• no employees;
• annual income does not exceed 834 minimum wages (~UAH 6.7 million in 2025);
• no trade in excisable goods.

General rate — 19.5% (18% PIT + 1.5% military levy) if any condition is unmet.

💳 Exemption for Small Transactions?

Yes. Individuals who:

• complete no more than 3 sales per year;
• earn less than €2,000 annually;

are exempt from opening a special account and do not fall under mandatory reporting.

🏦 How Will Bank Monitoring Work?

STS will have the right to request data from banks regarding special accounts, including:

• incoming payments;
• payer identification;
• payment purpose;
• counterparty details.

This is based on user consent when opening the account, aligned with AML/CTF standards and EU practice.

📌 Is This an IMF Requirement?

Yes. This draft law is part of the IMF “structural benchmarks.” Ukraine fulfilled the obligation to register it by April 2025. However, final adoption depends on further review and parliamentary committee feedback.

💬 Expert Opinion

According to Andriy Zablovskyi (Council of Entrepreneurs under the Cabinet of Ministers), technical revisions are likely before the second reading due to administrative and compliance concerns, especially with non-resident platforms.

🧩 GLS Law Commentary

If passed, this law will reshape digital economy taxation. If you:

• rent out property via Booking;
• freelance on Upwork or Fiverr;
• sell through OLX, Etsy, or Amazon;
• drive for Uber or Bolt;
• run microbusinesses via Prom —

you need to assess:

• whether your activity is reportable;
• if the preferential tax rate is available to you;
• how to open a special account and manage compliance.

GLS Law offers:

• legal case review;
• support in account setup;
• tax structuring under the new rules;
• double taxation risk assessment.