New taxation rules will be introduced in Ukraine from 2028: what will change for business

Ukraine plans to step up the fight against tax abuse and profit shifting abroad. The government has approved a bill that provides for the introduction of new tax control mechanisms in accordance with European standards.

The corresponding bill No. 16150 was registered in the Verkhovna Rada on October 15, 2026. The document was developed by the Ministry of Finance as part of the approximation of Ukrainian legislation to the requirements of the European Union.

The bill provides for the introduction of three main mechanisms to combat tax evasion.

Tax on the transfer of assets abroad

The first mechanism is Exit Tax. It provides for the taxation of the increase in the value of assets in cases where they are transferred outside Ukraine and the state loses the right to tax them.

The amount of the increase will be determined as the difference between the market value of the asset at the time of transfer and its value for tax purposes.

The new rules may apply when changing tax residency, transferring assets to foreign representative offices, or moving business activities outside Ukraine.

At the same time, the draft law provides for exceptions for certain temporary transfers of assets for a period of up to 12 months.

The tax authority will be able to check artificial transactions

The second mechanism is GAAR, a general rule for combating tax abuse.

It will allow regulatory authorities to assess transactions that formally comply with the law, but are actually aimed at obtaining unjustified tax benefits.

In such cases, the tax consequences will be determined taking into account the real economic content of the transactions.

At the same time, the tax service will be obliged to prove the fact of abuse.

To apply this mechanism, it is proposed to create a special permanent commission at the central office of the State Tax Service. Taxpayers will have the right to provide additional documents and involve experts.

Combating double tax advantages

The third mechanism will concern the so-called hybrid mismatches that arise due to differences in the tax legislation of different countries.

In particular, it is proposed to eliminate the possibility of double accounting of expenses or their accounting without corresponding taxation of income.

Thus, the state plans to limit the use of international schemes to artificially reduce tax liabilities.

When will the new rules come into force

The Ministry of Finance notes that the changes are aimed at protecting Ukraine’s tax base, preventing the transfer of profits to countries with lower taxation levels, and fulfilling European integration obligations.

The draft law takes into account the provisions of the European ATAD Directive and the recommendations of the Organization for Economic Cooperation and Development.

If the document is adopted, the new rules will begin to apply from January 1, 2028.

Currently, the draft law is at the legislative stage, so the proposed rules have not yet entered into force.