The Ukrainian National Committee of the International Chamber of Commerce (ICC Ukraine) and the Ukrainian Bar Association (UBA) have signed a Memorandum of Cooperation.

The document was signed by Tetiana Savosko, Executive Director of ICC Ukraine, and Mykola Stetsenko, Chair of the Ukrainian Bar Association.

The Memorandum provides for the development of partnerships between the legal community, business, and the expert environment, as well as the coordination of efforts to support professional dialogue, foster international cooperation, and contribute to the creation of a favorable legal and investment climate in Ukraine.

The organizations agreed to establish an information partnership, hold joint professional and educational events, and develop platforms for professional exchange of experience.

“Signing this Memorandum with the Ukrainian Bar Association is first of all about strengthening expert capacity, combining professional potential, and creating fundamentally new opportunities for the development of the legal, business, and international environment. For ICC Ukraine, it is important to build strong expert platforms where the synergy of knowledge, practical experience, and international cooperation will contribute to raising professional standards, developing competencies, and shaping effective solutions for Ukraine,” said Tetiana Savosko.

“It is extremely important for the UBA to foster cooperation with communities that bring together the business sector, the expert community, and international partners. We have been collaborating with ICC Ukraine for a long time, and I am convinced that signing this memorandum will help strengthen professional dialogue and advance the development of a modern legal environment in Ukraine,” emphasized Mykola Stetsenko.

We believe that this synergy will open up new opportunities for our members and partners. Many exciting initiatives lie ahead!

April 23, 2026, in Ivano-Frankivsk, the Integration Forum “Paths and Financing for the Recovery of Territorial Communities: Strategy 2026” took place.

Funding for reconstruction, the development of social housing, and the role of developers and municipalities were discussed during the RECOVERY CONSTRUCTION FORUM UKRAINE 3.0, which took place on April 22.

The International Chamber of Commerce Ukraine is an information partner of the forum. Representing ICC Ukraine at the event were Svitlana Devochkina (Vice Chair for Ukraine’s Reconstruction) and Andriy Romanov (ICC Ukraine Banking Commission).

“Russia’s aggression continues to destroy Ukraine’s infrastructure and housing stock. In these circumstances, building a transparent and open construction market is a key prerequisite for development and European integration. At the same time, reconstruction cannot be limited to the public sector — the private sector plays a critically important role and has already demonstrated its resilience. Given growing needs and limited financing, it is essential to strengthen cooperation and create favorable conditions for business participation in recovery efforts,” emphasized Francesco Floris, First Counsellor and Trade Counsellor at the Delegation of the European Union to Ukraine, welcoming participants of the forum.

Opening remarks were also delivered by Oleksandr Chervak, CEO of the Confederation of Builders of Ukraine, and Olena Kononenko, Director of ReBuild Ukraine and Aquatherm exhibitions.

“The world is ready to invest; however, investors do not choose countries — they choose clear rules, speed, and trust. Our key tasks are to develop investment-ready projects, ensure transparent and predictable rules, and think at scale — at the level of systems, cities, and the economy. We are already competing globally for capital, and the question is how fast, clear, and reliable we can be. Reconstruction will happen — the question is who will deliver it and how,” noted Lev Partskhaladze, President of the Confederation of Builders of Ukraine, opening the first panel on financing, priorities, and implementation mechanisms for recovery projects.

The panel was co-moderated by Oleksandr Slobozhan, Executive Director of the Association of Ukrainian Cities.

From Financing to Implementation: Regulatory Framework

Olena Shuliak, Chair of the relevant committee of the Verkhovna Rada of Ukraine, outlined key legislative and regulatory prerequisites for moving from financing to implementation:

“Ukraine already has basic strategic and budgetary documents for recovery; however, a critical challenge remains the lack of up-to-date urban planning documentation, without which project implementation is impossible. The speed of preparation depends largely on the capacity of local governments. Despite postponing mandatory spatial development plans until 2028, progress remains slow. Effective reconstruction requires combining high-quality urban planning with the development of public-private partnership mechanisms.”

Nataliia Kozlovska presented the Ministry’s vision for modernizing construction regulation, improving permitting procedures, and introducing advanced project implementation tools:

“We are working on a comprehensive transformation of the construction sector — from regulation and permitting to project delivery tools. Particular attention is given to quality and the implementation of BIM technologies, which will enable businesses to work more effectively with public funds. We are also simplifying urban planning documentation and advancing reforms to make the rules clear and practical for the market.”

Financing Priorities and International Support

Kristina Mikulova, Head of the regional representation of the European Investment Bank (EIB), outlined the Bank’s approach to financing recovery projects:

She stressed the urgent need to prepare high-quality, investment-ready projects, as demand for financing significantly exceeds available resources. Priority sectors include social and critical infrastructure, particularly housing and water supply. Key financing conditions remain transparency, zero tolerance for corruption, financial sustainability, and expanded access to European programs.

Oleksandr Novytskyi highlighted key barriers at the start of construction and steps toward simplification and digitalization. The State Inspectorate of Architecture and Urban Planning of Ukraine is working to expand automated registrations and develop digital tools, including an AI assistant for verifying project documentation and identifying inconsistencies.

Oleksandr Kubrakov emphasized recovery priorities and conditions for attracting investment, noting the crucial role of the private sector. He highlighted the need for clear investment rules, transparent tariff policies, and expanded cooperation with international partners to mitigate risks.

Roman Komendant outlined approaches to project implementation, focusing on systemic infrastructure projects in logistics and water supply, supported by digital tools such as the DREAM ecosystem. He stressed the importance of public-private partnerships and integrated, district-level reconstruction.

Serhii Korenev shared practical experience at the municipal level, including a master plan developed with the United Nations Economic Commission for Europe focusing on water, energy, and waste management, with projects implemented in cooperation with international partners.

Housing Policy: From Compensation to New Stock

The second panel focused on housing policy and was moderated by Serhii Mamedov.

Ivan Parukh outlined approaches to stimulating demand, including housing vouchers and support programs.

Serhii Komnatnyi emphasized the importance of using international support not only for financing but also for knowledge transfer and institutional capacity building, including the development of social housing and regulated rental markets.

Andrii Tarasenko discussed scaling the “eOselia” mortgage program, noting growing demand and limited supply.

Serhii Zakharov presented a concept for affordable rental housing for internally displaced persons, including a flagship project in Bila Tserkva for over 1,100 families.

Dmytro Levytskyi outlined new approaches to social housing, emphasizing sustainability, inclusiveness, and financial viability, including a €100 million pilot project to build 1,500 apartments.

Business Access to Recovery Projects

The third panel, moderated by Denys Verhun and Ivan Slobodianyk, focused on practical tools for business participation in recovery projects.

Vitalii Petruk outlined key instruments supporting businesses in 2026, including the “Made in Ukraine” policy, localization, the “5–7–9%” financing program, and insurance and compensation mechanisms via the Export Credit Agency.

Mykola Ilinov highlighted program requirements and results, noting that total grants disbursed have reached UAH 4.7 billion.

Tetiana Korotka emphasized the growing number of business inquiries related to recovery projects and the importance of compliance, which is often underestimated by Ukrainian companies and limits their access to international contracts.

She stressed that effective participation requires a comprehensive approach, including strong infrastructure, access to financing, clear regulation, and reasonable participation costs.

Conclusions

Participation in Recovery Construction Forum 2026 confirmed that Ukraine’s recovery has moved from planning to active implementation. Direct dialogue with key stakeholders — including representatives of the government, Ukrainian cities, the EU, and the EIB — provided valuable insights into new initiatives, practical steps, programs, and financial instruments for restoring industrial capacity.

The forum proved to be an effective platform demonstrating that large-scale construction and modernization are already underway, while consolidated support from the government, municipalities, and international partners provides a solid foundation for remaining work, emphasized Andrii Romanov.

Organizers: Confederation of Builders of Ukraine and Premier Expo, an international exhibition operator

General Partner: Creator-Bud

Strategic Partner: XModule, Solidarity

Financial Partner: Globus Bank

Official Partners: Penetron Ukraine, Caparol Ukraine, TsGIP, Ruukki Ukraine

Media Partner: ICC Ukraine

Dispute Resolution in M&A Transactions INTERNATIONAL CONFERENCE 2026 (8th edition)

Date: 21–22 May 2026

Location: Polish History Museum, Warsaw, Poland

Registration and details: www.disputeresolutionmaconference.com

The 8th edition of the Dispute Resolution in M&A Transactions INTERNATIONAL CONFERENCE is a well-established biennial forum dedicated to the practical realities of post-transaction disputes. The conference brings together an international community of dispute resolution and transactional lawyers, arbitrators, in-house counsel and M&A professionals to discuss how M&A disputes are handled in arbitration and related proceedings.

The 2026 programme will focus on current developments in post-M&A disputes, evolving advocacy standards and decision-making in arbitration, as well as valuation and damages issues. It will also address the broader ecosystem surrounding arbitration, including the role of state courts, witness examination, document production, and cross-tradition friction points, as well as explore the broader geopolitical and legal implications of the Ukraine–United States mineral resources agreement.

The conference is organised by ICC Arbitration, ICC Poland, and GESSEL Attorneys at Law, with the support of leading international law firms and advisers, including Clifford Chance Poland, Dentons w Polsce, and Legora as Grand Partners, as well as Legora as Gala Dinner Partner, and BLSK Legal, CMS Poland, FORDATA Virtual Data Room, Freshfields, MGW Corporate Consulting Group, and Moore Polska as Partners.

Some conversations are simply worth being in.

The past two days have been particularly significant for us. ICC Ukraine, represented by Dmytro Khoruzhnyi, joined colleagues from across Europe and the ICC global headquarters in Paris at a meeting hosted in London by ICC United Kingdom, the Regional Coordinator of the ICC European Advisory Group.

Delegates from over 26 countries gathered around one table — and it was important for Ukraine to be among them. The event opened with a reception at the UK Parliament, setting the tone for the entire programme: a shared sense of purpose and the strength of the ICC global network.

From Ukraine to Armenia, from Scandinavia to Central and Eastern Europe, alongside partners from the G7 countries, discussions over the two days reinforced a simple but fundamental idea: in an increasingly unpredictable world, cooperation must matter more, not less.

As noted by the Chairman of ICC United Kingdom, Karan Bilimoria, the time has come to move forward together with clarity and confidence. Meanwhile, ICC Secretary General John W. H. Denton emphasized that business plays a crucial role in ensuring that trade remains open and continues to support growth, jobs, and stability.

For ICC Ukraine, these issues are far from abstract. Open trade, access to finance, and the digitalization of trade processes are essential for Ukraine’s economic recovery and its integration into the European market. We are grateful to our colleagues at ICC United Kingdom for the opportunity to bring the voice of Ukrainian business to the European agenda.

The focus of discussions was on practical action: moving from fragmentation to results, from ambition to solutions that truly work for companies of all sizes. Strengthening the trading system, advancing digital trade, and addressing the global trade finance gap were central themes — with a consistent message: progress begins with partnership.

We thank ICC United Kingdom for the excellent organization and all colleagues for the meaningful discussions. We look forward to continuing this work together.

On April 16, 2026, a key industry event for the financial sector — Forbes Banker 2026 — took place in Kyiv, bringing together leading bankers, business representatives, government officials, and experts.

ICC Ukraine was represented at the event by Secretary General Oleksii Kozhanov and Executive Director Tetiana Savosko.

Discussions focused on the strategic challenges facing the financial sector amid the prolonged war, rising tax pressure, and the need to build a resource base for Ukraine’s future recovery.

Balancing Fiscal Pressure and Economic Development

One of the key messages of the conference was the need to shift from short-term fiscal thinking to a long-term development strategy for the financial system.

Governor of the National Bank of Ukraine, Andriy Pyshnyi, emphasized the systemic role of the banking sector as one of the largest taxpayers and a key driver of the economy.

At the same time, market participants stressed that excessive tax pressure — including a potential rate of up to 50% — could significantly limit banks’ ability to build capital and finance investment projects as early as 2027.

For the international business community represented by ICC, the predictability of tax policy remains a critical factor in attracting foreign investment.

Business Expectations: Speed, Trust, and Partnership

Conference participants highlighted a shift in business expectations toward banks:

• for mid-sized businesses — reliability and speed of decision-making remain key priorities;
• for large businesses — long-term partnerships and flexibility in financing approaches are essential.

Particular attention was paid to simplifying financial monitoring procedures and developing digital services, both crucial for integrating Ukrainian businesses into global markets.

These trends directly align with ICC’s priorities in facilitating international trade and developing efficient financial instruments.

Economic Drivers: Defense, Energy, and Consumption

The banking community identified key sectors that will drive demand for financing in 2026–2027:

• the defense industry (including Military Tech),energy,
• domestic consumption.

The growing importance of dual-use goods was also highlighted — a segment requiring new approaches to risk assessment and financing.

European Integration and Banking Sector Transformation

Another important topic was the adaptation of Ukrainian banks to European standards as a prerequisite for attracting strategic investors and integrating Ukraine into the EU financial space.

Digitalization, improving the efficiency of banking networks, and harmonizing regulatory procedures were identified as key directions for sector transformation.

ICC Ukraine Position

Participation of ICC Ukraine in Forbes Banker 2026 reaffirms the organization’s active role in shaping dialogue between business, the financial sector, and the government.

ICC Ukraine consistently supports:

• the creation of a predictable tax environment;
• improved access to finance for businesses;
• integration of the Ukrainian market into the global economy;
• strengthening institutional capacity for post-war recovery.

The participation of ICC Ukraine’s leadership in the event was an important part of this effort and contributed to strengthening engagement with key stakeholders in the financial market.

At St. Sophia Cathedral, President of Ukraine Volodymyr Zelenskyy and First Lady Olena Zelenska met with orphaned children from Kyiv and the Kyiv region whose parents gave their lives for our country.

Volodymyr and Olena Zelenskyy spoke with the children and presented them with gifts on the occasion of Easter.

For the young Ukrainians at St. Sophia Cathedral, an excursion and a quest were organized, during which they searched for pysanky (Easter eggs) on the grounds of the national reserve. The children also sang vesnyanky and hayivky (traditional spring songs) and participated in a stained-glass making workshop.

“We want to congratulate you on all the holidays. We certainly wish you warmth, kindness, and light. You have such wonderful smiles—don’t lose them. And we wish you all victory,” the Head of State noted.

The event took place as part of the “Children of Our Defenders” charitable platform for socially responsible business, which has united nearly 90 business representatives and entrepreneurs with the state. With the support of the Ministry of Veterans Affairs of Ukraine, the State Service of Ukraine for Children, and the International Chamber of Commerce of Ukraine, they care for orphaned children in various regions of Ukraine. Specifically, they organize excursions, entertainment events, and vacations in camps.

The President emphasized that during the war, it is vital for businesses and entrepreneurs to be socially responsible and support children whose parents gave their lives defending Ukraine from russian aggression.

Source: https://www.president.gov.ua/news/prezident-i-persha-ledi-privitali-z-velikodnem-ditej-zagibli-103801 (The President and the First Lady wished a Happy Easter to the children of fallen heroes)

“Children of Our Defenders” Platform: https://children.in.ua/pidtrymka/ (Support for the “Children of Our Defenders” Platform)

A High-Level Roundtable on Revitalising the Multilateral Trading System: Europe took place in Brussels—a high-level discussion organized by the International Chamber of Commerce (ICC) in collaboration with Eurochambres. The event gathered leading representatives of international institutions, governments, European institutions, and the business community to discuss the future of the global trading system.

Ukraine’s participation in such events is about the state’s voice in shaping new rules for the global economy, integration into international trade processes, and advocating for its own economic interests in a complex geopolitical environment.

Among the key topics of discussion:

• the role of international institutions in the new geoeconomic reality

• the impact of global political changes on trade policy

• the future of the multilateral trading system after MC14

• the vision of the European Commission and the European Parliament regarding the development of global trade

Speakers of the event:

• Philippe Varin — Chair of the International Chamber of Commerce (ICC)

• John W.H. Denton AO — Secretary General of the ICC

• Ömer Bolat — Minister of Trade of Türkiye

• Vladimír Dlouhý — Chair of Eurochambres

• Maria Martin-Prat de Abreu — Deputy Director-General of DG Trade, European Commission

• Jörgen Warborn — Member of the European Parliament, Co-Chair of the Steering Group of the Parliamentary Conference on the WTO

• Anna Jerzewska — Head of Trade and Borders, expert on international trade issues

• Julian Kassum — Deputy Secretary General of the ICC (Network)

Representing ICC Ukraine at the event was Daria Lazareva — Advisor to the Secretary General of ICC Ukraine on legal Ukrainian practice, Advisor at ETERNIX Law Firm, and member of the Committee on Business and Investor Protection of the UNBA.

We thank Eternix Law Firm for its active international engagement and support of ICC Ukraine’s activities—it is thanks to such participants that Ukrainian business is heard at the global level.

Ukraine’s economy has entered a phase where budgetary support alone is no longer sufficient. Businesses need long-term capital, war risk insurance, predictable investment rules, and effective mechanisms to stimulate small and medium-sized enterprises. According to estimates by the Ministry of Economy, Ukraine’s real GDP declined by 1.2% in January–February compared to the same period in 2025, while the banking sector recorded UAH 17.783 billion in profit during the first two months of 2026. This gap highlights a structural imbalance in incentives. It is currently more выгодно for banks to maintain high liquidity and work with government instruments than to engage in complex, long-term projects in the real sector.

The profitability of the banking system itself is not in question. A strong banking sector must be profitable, well-capitalized, and resilient. The issue lies elsewhere. Bank profits remain weakly linked to the large-scale launch of new production, technological modernization, and investment lending. This indicates that the core problem lies in incentives and risk allocation. Bank profitability, in this context, is secondary.

Describing the current situation as a general contraction in lending is no longer accurate. In 2025, net hryvnia-denominated loans to businesses and households increased by more than one-third. Even more importantly, market-based lending grew faster than loans subsidized under the “5–7–9%” program, and the share of concessional loans in the hryvnia portfolio declined. Therefore, the key deficit today concerns long-term investment resources, war risk coverage, project finance, and lending to companies lacking strong collateral or operating in sectors with longer payback cycles. According to the National Bank of Ukraine, in 2022–2023 the banking sector demonstrated resilience and even profitability, largely due to investments in domestic government bonds (OVDP). This model is understandable in wartime conditions: the state requires financing, while banks seek low-risk instruments.

This is where the key contradiction emerges. During the war, the state has naturally become the largest borrower and the dominant player in the financial system. By the end of 2025, state-owned banks still accounted for around 52% of the sector’s net assets. Under such a configuration, the government, the regulator, and state-owned banks effectively shape most of the rules of the game. For businesses, this means a narrower competitive space, slower development of private financing instruments, and greater dependence on budgetary decisions.

This is why simply scaling up the “5–7–9%” program does not appear to be an adequate response. Preferential rates are useful as an anti-crisis tool, but they do not create a полноценний capital market. When the state becomes the primary discounter of the cost of money, the market loses its risk-pricing signal. Resources tend to flow toward areas supported by budget compensation, and maximum productivity ceases to be the main criterion for capital allocation. As a result, businesses become accustomed to politically determined rates, while banks adapt to state-driven demand architecture.

Ukraine needs a different focus. State support should concentrate on risks that the private market is unwilling to assume independently during wartime. These include partial guarantees, first-loss mechanisms, war risk insurance, export insurance, and joint instruments with international financial institutions. This approach is already working within European and global programs. The European Union’s Ukraine Investment Framework provides €9.5 billion in financial instruments and aims to mobilize over €40 billion in investments. The International Finance Corporation (IFC) in 2025 signed a €100 million risk-sharing agreement with Credit Agricole Ukraine to expand business lending. The European Bank for Reconstruction and Development (EBRD) increased its financing for Ukraine to a record €2.9 billion in 2025, with 57% directed to the private sector.

The practical conclusion is clear: Ukraine needs precise risk reduction mechanisms for private capital. Further expansion of state dirigisme in lending will only entrench existing distortions. The state must create a framework in which it is выгодно for banks to finance manufacturers, exporters, processors, logistics businesses, energy projects, and technology companies. This requires predictable taxation, strong creditor rights protection, effective collateral enforcement, transparent guarantee mechanisms, and rapid solutions for war risk insurance.

A separate issue concerns the role of state-owned banks. As long as the state controls more than half of the sector’s net assets, it is premature to speak of mature competition. Wartime conditions explain this configuration, but they do not negate the strategic objective. After stabilization, the state’s share in the banking sector should gradually decrease. Otherwise, the credit system will continue to gravitate toward budget financing, crowding out market-based risk assessment.

Ukraine’s recovery will require a massive volume of private capital. According to IFC estimates, the private sector could cover up to 40% of reconstruction needs. Therefore, the key objective of financial policy is to make bank lending, direct equity investment, quasi-equity, and long-term investment instruments standard practice. A strong recovery economy emerges where the state insures extreme risks, international partners multiply private resources, and competition for borrowers functions effectively.

Ukraine will succeed when the budget ceases to be the sole major driver of financing, and private capital gains real incentives to enter the country, its industries, its emerging startups, and its innovation ecosystem. This model will ensure both resilience during the war and sustainable economic growth afterward.

Volodymyr Klymenko
Vice Chair for Regional Development and Investment & Grant Policy
ICC Ukraine
Chairman of the Banking Commission, ICC Ukraine

The following is the translation of the article by Dmytro Oleksiyenko, Chairman of the ICC Ukraine Tax Commission, published in Censor.NET. The author focuses on key aspects of the interaction between business and the state, highlighting the most acute issues that require the attention of the expert community and the authorities today.

At the end of 2025 – beginning of 2026, the International Monetary Fund was supposed to approve a new program for Ukraine in the amount of 8.1 billion USD. However, the Cabinet of Ministers’ proposals, previously agreed upon with the IMF, turned out to be so unacceptable for Ukrainian businesses and citizens that they did not find the necessary support among parliamentarians, who were asked to vote for these unpopular steps.

It should be recalled that a staff-level agreement between the IMF and the Ukrainian government was reached back in November 2025. But the Ministry of Finance, judging by the public testimony of deputies, did not conduct any systematic work with parliamentary factions to explain the content of the bills and ensure the necessary support. Instead, leading business associations and economic experts subjected the new taxes to devastating criticism.

Key proposed changes included: the introduction of VAT for Individual Entrepreneurs (FOPs) with a turnover exceeding 1 million UAH; the cancellation of the tax exemption for parcels up to 150 euros; the adoption of a law on the taxation of digital platforms; and the fixation of the 5% military levy even after the end of martial law.

Prime Minister Yuliia Svyrydenko stated on February 13 that certain compromises had been reached in the dialogue with the IMF — particularly regarding the VAT threshold for FOPs. There is also a discussion regarding moving tax changes from the status of prior conditions for program approval to the status of structural benchmarks.

Of the four key requirements of the new IMF program, the issue of VAT for individual entrepreneurs caused the greatest public outcry. The initial threshold of 1 million UAH per year was unrealistic: at this level, 670,000 FOPs would fall under mandatory VAT registration. The effective tax rate for them would have tripled — from approximately 6–7% today to 20–22%, if counting the single tax, military levy, and VAT together.

The current compromise consists of raising the threshold to 4 million UAH, which reduces the list of potential new VAT payers to approximately 260,000 entrepreneurs. The proposed figure for introducing VAT corresponds to the maximum threshold for VAT exemption for small businesses established by the EU Directive for small enterprises — 85,000 euros per year. At the current exchange rate, this is exactly about 4 million UAH.

Separately, it is worth noting: the threshold in hryvnias will devalue over time, while the real level of income will grow. To prevent the reform from turning into a mechanism for the constant expansion of the circle of VAT payers through inflation, a more rational decision would be to immediately fix the threshold directly in euros — given Ukraine’s declared course toward EU membership.

Raising the VAT threshold, however, does not solve the key problem — the administrative burden. VAT is one of the most complex taxes in terms of accounting, reporting, working with VAT invoices, and the risk of blocked accounts. For FOPs providing services, the transition to VAT means either a significant price increase for clients or a sharp decrease in profitability. For retail — an increase in retail prices. Without simultaneous simplification of the administration itself, VAT registration will turn into an additional incentive for the shadow economy.

The second block of tax reforms concerns the taxation of income received through digital platforms — taxi aggregators, marketplaces, rental, and freelance services. The government’s logic here seems more understandable: a significant volume of income in this sector exists in the shadows, while digital platforms have full information about all transactions. The digital economy in Ukraine is growing, and its taxation is justified. However, there are serious questions in the details of implementation.

First, the question of who will actually pay the new taxes. The experience of introducing VAT on electronic services of foreign companies in 2021 — the so-called “Google tax” — showed: large digital platforms do not absorb new fiscal costs but pass them on to consumers through increased prices or commissions. Streaming services, app stores, cloud platforms — everyone raised prices for Ukrainian users by exactly 20%. There is reason to expect that the new taxation for platforms will lead to an analogous result: commissions for sellers will increase, and they will raise prices for buyers. The average Ukrainian will remain the ultimate payer.

Second, the administrative burden placed on platform operators is disproportionate to the scale of their activities. A large international marketplace and a small local apartment rental service will receive the same obligations: to collect and verify the data of sellers and buyers, store it for five years, report quarterly, and in case of non-compliance — receive a fine in the amount of one hundred minimum wages. For small operators, this will be a critical burden that will jeopardize business profitability.

Third, the bill grants the State Tax Service (STS) new powers to access the banking information of accountable sellers, and the boundaries of this access are formulated quite broadly. In a country where the practice of arbitrary actions by tax authorities has long been documented by both the business community and the ombudsman, this is not a rhetorical problem.

A sensible solution would be phased implementation: first, voluntary connection to the data exchange system with tax incentives for participation, then a gradual transition to a mandatory regime. And most importantly — a parallel reform of the STS, which would make interaction with the tax authorities predictable and devoid of corruption risks.

The third issue — the cancellation of the customs exemption for parcels worth up to 150 euros — is the least justified in terms of both implementation timing and fiscal logic itself.

For example, in the EU, this discussion exists in a fundamentally different context: a single market, developed customs infrastructure, and a real competitive threat to local producers from Asian platforms. In Ukraine, a significant portion of parcels in this price range are personal use goods, gadgets, spare parts, as well as supplies for the front.

The fiscal effect of this measure will be limited and stretched over time — the administration of massive small parcels requires customs infrastructure that the State Customs Service currently does not have in sufficient volume. Instead, the social effect — the growth of retail prices — will manifest immediately and affect primarily the poorest segments of the population.

It is worth calling things by their names: the real lobbyists for this change are domestic retailers, interested in selling the same Chinese goods to Ukrainians through their own networks — and with a corresponding markup. This interest is quite understandable, but it should not be masked by fiscal arguments.

An alternative that achieves the same goal without a massive blow to the consumer exists: quantitative limits on exempt parcels per person per month or year. This approach is practiced in a number of countries and allows for separating personal consumption of such goods from commercial consumption.

The fourth block of reforms — fixing the 5% military levy rate after the conclusion of martial law — is the most strategically significant and at the same time the least publicly discussed. The current legal structure assumes that the 5% rate, introduced in December 2024, is temporary: after the cancellation of martial law, the levy automatically returns to 1.5%. The IMF insists on fixing the increased rate permanently — at least until the formal conclusion of hostilities and budget stabilization.

Arguments in favor of such an approach exist. In 2025, in the first four months alone, receipts from the military levy amounted to 163.6 billion. This is a significant source of income, and its sudden reduction, when defense spending needs remain substantial, represents a serious fiscal gap.

However, the question of the time horizon and conditions arises here. Permanently fixing the 5% rate — not as a transitional but as a base rate — contradicts the logic of post-war recovery. Private investments are sensitive to the level of taxation. A military levy rate of 5%, superimposed on the base Personal Income Tax (PIT) rate of 18%, gives an effective taxation level for personal income of 23%. This is noticeably higher than in most competitor countries for foreign direct investment in the region. After the war ends, Ukraine will compete for investors and specialists, and the level of labor taxation is one of the key factors of this competition.

A sensible construction would look different: maintain the 5% rate for a clearly defined transition period — say, 3–5 years — with an automatic reduction after reaching defined budgetary goals. This would provide guarantees of revenue in the medium term, and for investors — a predictable horizon. Instead, the indefinite fixation of the increased rate carries the risk of freezing the wartime fiscal model in peacetime.

Behind each of the four discussions — VAT for FOPs, digital platforms, parcels, military levy — the same systemic flaw is visible: Ukraine is trying to expand the tax base without simultaneously reforming the institutions that make compliance with tax obligations costly and unpredictable.

The real reason why businesses use FOPs is not that extremely favorable tax rates exist, but that the price of scaling is extremely high. This is not only increased tax rates but also the corruption risk during audits, blocked VAT invoices that have to be fought for for months, the STS’s own interpretation of norms to the detriment of the taxpayer, and the bureaucratic complication of reporting that forces even a small FOP to keep an accountant.

In the broader context of reforms required by the IMF program, it is worth asking a question that remains outside the technical discussions: is the very logic of fiscal consolidation, which shifts the main burden onto small business and the middle class, correct?

Ukraine has been carrying a security burden of continental scale for almost five years, deterring Russian armed aggression and protecting Europe. At the same time, international support comes primarily in the form of loans, not grants — even where strategic and moral logic would require a different approach. More than 300 billion USD of the aggressor state’s frozen assets remain virtually untapped as a source of reparations, despite all public declarations of the intent to use them.

Inside the country, alternative sources of fiscal mobilization remain largely unrealized. Customs smuggling of tobacco, alcohol, and fuel is a source of billions in budget losses that the customs and the STS have for years been unable or unwilling to shut down. Offshore schemes of large businesses remain. Royalty payments for the extraction of mineral resources in a number of sectors remain below international market values.

The choice to focus fiscal pressure on small businesses and employees — that is, on those who have neither lobbyists nor offshore jurisdictions — is not an economic necessity but a conscious choice by both international institutions and the Ukrainian government.

If the government truly aims to adopt a consolidated bill in the coming weeks covering all four blocks of IMF requirements, it will have to do at least three things it has avoided so far.

First — conduct real consultations with business associations, experts, and parliamentary committees before, not after, key decisions are made. Second — clearly define the conditions and terms for each norm coming into force: uncertainty for business costs more than any rate. Third — parallel to raising rates and expanding the base, present a concrete program for reforming the administration itself: simplifying VAT reporting and genuinely reforming and resetting key fiscal bodies.

Source: https://censor.net/ua/b3601977