Tax stability during wartime proposed to be enshrined in law: alternative bill registered in the Rada

The Verkhovna Rada of Ukraine registered draft law No. 15112-3 dated April 5, 2026, which provides for the introduction of a temporary moratorium on changing key elements of taxes and fees for the period of martial law and for one year after its end.

The initiative is aimed at ensuring the stability of tax legislation in wartime, when Ukrainian business operates in an environment of increased risks, logistical restrictions and personnel shortages.

The essence of the legislative initiative

The document proposes to supplement subsection 10 of Section XX “Transitional Provisions” of the Tax Code of Ukraine with a new paragraph prohibiting changes to elements of taxes and fees. This concerns, in particular:

taxpayers;
objects and tax base;
rates;
calculation procedure;
tax periods;
payment terms and procedure.

The moratorium is proposed to be applied for the entire period of martial law introduced in 2022, as well as for a year after its end or cancellation.

Expected effect for business

The authors of the bill emphasize that frequent changes in tax rules during the crisis create additional pressure on entrepreneurship. At the same time, the stability of the legislation should contribute to:

reducing the regulatory burden;
increasing the predictability of doing business;
improving the investment climate;
preserving jobs.

At the same time, the bill does not provide for the abolition of existing taxes or exemption from their payment, but only fixes the immutability of their main parameters.

Remarks of parliamentary experts

The Main Scientific and Expert Department of the Verkhovna Rada Office drew attention to the fact that the proposed norm is mainly declarative in nature. In particular, it is emphasized that the Constitution of Ukraine does not limit the powers of the parliament to amend laws, and therefore, even in the event of a moratorium, further adjustments to tax legislation are theoretically possible.

Among other comments:

risks for balancing budget indicators in the event of the impossibility of changes;
uncertainty regarding the extension of the moratorium to local taxes;
the need to clarify the subject of regulation and the status of the draft law.
When can it come into force

If adopted, the law should enter into force on June 1, 2026. The Cabinet of Ministers of Ukraine will be obliged to bring subordinate legislation into line with the new provisions.