The EBA generally supports the government’s tax draft laws

07/ 04/ 2026

Experts of the European Business Association have reviewed a comprehensive package of tax draft laws initiated by the Cabinet of Ministers of Ukraine. The Association conceptually supports these initiatives, while also putting forward a number of comments and proposals. Regarding the abolition of the VAT exemption for goods valued up to EUR 150 (Draft Law No. 15112) The Association’s experts conceptually support the abolition of preferential VAT treatment for parcels. At the same time, they propose preparing relevant amendments to the Customs Code of Ukraine in order to introduce a simplified procedure for administering the respective customs payments. The Association has repeatedly appealed to the Government, Parliament, and other public authorities to revise VAT exemptions for the import of goods valued at up to EUR 150. Such a step would, in particular, help align Ukrainian tax and customs legislation with the rules of the European Union. Regarding the introduction of international automatic exchange of information on income earned via digital platforms (Draft Law No. 15111) The Association believes that certain provisions of Draft Law No. 15111 require clarification, primarily with regard to defining who qualifies as a digital platform operator and a reportable seller as a business entity. In addition, the Association’s experts consider it inappropriate to introduce special bank accounts, as well as to disclose banking secrecy of reportable sellers of goods and services. In their view, such measures may increase social tension and undermine public trust. Regarding the military levy (Draft Law No. 15110) The Association believes that the future configuration of the military levy should be considered in a broader context — alongside a review of approaches to personal income taxation and social insurance. A piecemeal extension of increased rates without comprehensive reform risks entrenching existing imbalances and may further incentivise the shadowing of income. Experts warn that maintaining an elevated tax burden on payroll without systemic changes and without taking into account the macroeconomic situation during the post-war recovery period may slow economic growth, labour market recovery, and income formalisation. The Association welcomes the fact that, during the consideration of these initiatives by the Verkhovna Rada Committee on Finance, Taxation and Customs Policy, Members of Parliament took into account certain proposals from the Association, particularly when revising the draft laws on the taxation of digital platforms and the abolition of VAT exemptions on imported goods. The business community will continue to monitor the further consideration of these initiatives in the Verkhovna Rada. Overall, the Association’s business community is interested in identifying effective solutions to reduce the shadow economy and ensure a fair tax burden, including in the context of legislative initiatives aimed at preventing the misuse of the simplified taxation system for tax evasion. The Association consistently supports government measures aimed at creating a level playing field, increasing the predictability of the tax and regulatory environment, and developing mechanisms to counter the shadow economy without placing undue pressure on compliant taxpayers. An open and structured dialogue between the authorities and the business community will contribute to the adoption of balanced decisions that combine fiscal efficiency with a favourable business climate.

Regarding the abolition of the VAT exemption for goods valued up to EUR 150 (Draft Law No. 15112)

The Association’s experts conceptually support the abolition of preferential VAT treatment for parcels. At the same time, they propose preparing relevant amendments to the Customs Code of Ukraine in order to introduce a simplified procedure for administering the respective customs payments.

The Association has repeatedly appealed to the Government, Parliament, and other public authorities to revise VAT exemptions for the import of goods valued at up to EUR 150. Such a step would, in particular, help align Ukrainian tax and customs legislation with the rules of the European Union.

Regarding the introduction of international automatic exchange of information on income earned via digital platforms (Draft Law No. 15111)

The Association believes that certain provisions of Draft Law No. 15111 require clarification, primarily with regard to defining who qualifies as a digital platform operator and a reportable seller as a business entity.

In addition, the Association’s experts consider it inappropriate to introduce special bank accounts, as well as to disclose banking secrecy of reportable sellers of goods and services. In their view, such measures may increase social tension and undermine public trust.

Regarding the military levy (Draft Law No. 15110)

The Association believes that the future configuration of the military levy should be considered in a broader context — alongside a review of approaches to personal income taxation and social insurance. A piecemeal extension of increased rates without comprehensive reform risks entrenching existing imbalances and may further incentivise the shadowing of income.

Experts warn that maintaining an elevated tax burden on payroll without systemic changes and without taking into account the macroeconomic situation during the post-war recovery period may slow economic growth, labour market recovery, and income formalisation.

The Association welcomes the fact that, during the consideration of these initiatives by the Verkhovna Rada Committee on Finance, Taxation and Customs Policy, Members of Parliament took into account certain proposals from the Association, particularly when revising the draft laws on the taxation of digital platforms and the abolition of VAT exemptions on imported goods. The business community will continue to monitor the further consideration of these initiatives in the Verkhovna Rada.

Overall, the Association’s business community is interested in identifying effective solutions to reduce the shadow economy and ensure a fair tax burden, including in the context of legislative initiatives aimed at preventing the misuse of the simplified taxation system for tax evasion. The Association consistently supports government measures aimed at creating a level playing field, increasing the predictability of the tax and regulatory environment, and developing mechanisms to counter the shadow economy without placing undue pressure on compliant taxpayers.

An open and structured dialogue between the authorities and the business community will contribute to the adoption of balanced decisions that combine fiscal efficiency with a favourable business climate.