Charitable Support from Businesses: Documents, Accounting, and Taxes in Ukraine

Before providing charitable support, determine who is acting as the donor, whom they are helping and for what purpose, what exactly is being transferred, and which tax system applies. Then document the basis for the transfer, confirm the actual payment or acceptance of property or services, and calculate the tax consequences. The word “charity” in a payment reference or acceptance certificate does not, by itself, exempt a transaction from all taxes.

The rules below apply to businesses operating under Ukrainian law. A company’s or individual entrepreneur’s own charitable support, collecting donations from customers, and importing a humanitarian shipment require different documents. In practice, it is convenient to create a separate file for each transfer, from checking the recipient through to the bank statement, signed certificate, and relevant tax reporting.

Identify the parties, purpose, and form of support

Under Articles 1 and 3–5 of Law of Ukraine No. 5073-VI “On Charitable Activities and Charitable Organizations”, a donor may be a legally capable individual or a private-law legal entity. A regular private company can therefore provide support without setting up its own foundation. The support must be voluntary, serve lawful charitable purposes, and not provide the donor with profit, remuneration, or compensation from the recipient.

Subparagraph 170.7.7 of the Tax Code of Ukraine prohibits providing support to state authorities, local self-government bodies, nonprofit organizations established by them, or third parties acting on their instructions if the support is a condition for obtaining a permit, licence, approval, public service, or another decision in the donor’s favor, or for expediting the relevant process.

A recipient of support may be an individual, a nonprofit organization, or a territorial community. The law also allows charitable organizations to support other legal entities to achieve the purposes specified by law. A regular trading company should therefore separately check the legal structure of a transfer before giving property to another commercial enterprise.

1. Record the donor’s full legal name. If a company is providing support, the documents and payment must substantiate the company’s transaction. An owner’s personal transfer requires separate documentation.
2. Identify the direct recipient and, if a foundation or other organization will distribute the support, the ultimate beneficiaries.
3. State a specific purpose within the scope of Article 3 of Law No. 5073-VI, such as providing food to people in difficult life circumstances or supporting defense capabilities.
4. Specify what is being provided: money, goods, work, services, or the right to use property. Decide how the transfer will be documented for each item.
5. Before the transfer, inform the accountant of the recipient’s status, the amount or value of the support, the donor’s tax system, and whether the donor is registered as a value-added tax (VAT) payer.

An ordinary charitable donation is documented under Law No. 5073-VI and civil law. Humanitarian aid is governed by the special regime in Law No. 1192-XIV, which covers participant status, recognition of aid, accounting, and use controls. If a store transfers its own inventory to a Ukrainian foundation, calling it “humanitarian aid” on a delivery note does not, by itself, bring the transfer under this regime.

Check the recipient’s status on the transfer date

For a legal entity, check its full legal name, registration code, bank details, and the signatory’s authority. If the tax treatment depends on nonprofit status, retain evidence that the recipient was included in the Register of Nonprofit Institutions and Organizations on the date the money was transferred or the goods, work, or services were provided. Subparagraphs 140.5.9 and 166.3.2 and paragraph 72 of subsection 4 of Section XX of the Tax Code of Ukraine (TCU) expressly tie the rules to that date.

Practical recommendation. Keep registry evidence with the documents for the specific transaction. Separately record whether the recipient is specifically a charitable organization: a nonprofit public association and a charitable foundation may have different implications for the tax calculation.

If a representative collects the goods, check the document authorizing that person to accept property on the recipient’s behalf. Paragraph 2.4 of Regulation of the Ministry of Finance of Ukraine No. 88 allows authority to be confirmed, among other things, by a contract, power of attorney, or act of a legal entity’s governing body. A carrier’s driver is not always authorized to sign the recipient’s final acceptance certificate for the support.

Document the purpose and arrangements without imposing unnecessary universal requirements

Article 6 of Law No. 5073-VI defines a charitable donation as the gratuitous transfer of money, property, or property rights for charitable purposes agreed in advance. Under Article 729 of the Civil Code of Ukraine, a donation agreement is considered concluded when the donation is accepted. A signed agreement for a future transfer therefore does not yet prove that the recipient has received the support.

Practical recommendation. For recurring support or a substantial shipment, enter into a separate written agreement. Specify the parties, item and quantity, purpose, that the transfer is entirely gratuitous, the timing and place of transfer, authorized representatives, acceptance and reporting procedures, and the return of unused funds. If a foundation will distribute goods, agree on the report format and list of supporting documents. The donor may monitor the donation’s use for its intended purpose; any change of purpose must be documented with due regard to Article 6 of Law No. 5073-VI and Article 730 of the Civil Code.

A recipient’s request letter helps substantiate the need, while a manager’s decision can specify the authorized amount and the responsible employees. However, a separate request letter and order for every ordinary donation are not universal requirements in all cases. Whether a decision by a particular governing body is required must be checked against its authority, founding documents, and the enterprise’s procedures. For humanitarian aid, Article 3 of Law No. 1192-XIV expressly requires a donor’s written offer and the recipient’s written consent.

When written form or notarization is required

Article 719 of the Civil Code sets different rules depending on the subject of the gift. A gift of real estate requires a written agreement and notarization; a gift of a property right and an agreement requiring a gift to be transferred in the future must be in writing. A gift of movable property of particular value also requires written form, subject to the rule that an actual transfer under an oral agreement may be lawful.

Part Five of Article 719 concerns gifts of currency valuables between individuals exceeding 50 non-taxable minimum incomes. For this rule, one minimum is UAH 17, making the threshold UAH 850. At the same time, Part One of Article 6 of Law No. 5073-VI expressly exempts charitable donation agreements involving currency valuables from mandatory notarization. It is therefore incorrect to extend the notarization requirement to every charitable cash donation over UAH 850.

Under Article 208 of the Civil Code of Ukraine, transactions between legal entities must be in writing. A transaction between a company and an individual must also be in writing, except for cases permitted by Part One of Article 206 where the parties fully perform it at the time it is made. Apply the specific form requirements for the donation agreement according to its subject.

Under Article 207, a written arrangement may be recorded in one or more documents, including electronic documents, bearing the parties’ proper signatures. Therefore, a separate agreement in two paper copies is not a universal requirement, but the required written form must be ensured regardless of the amount of support. Confirm the transfer with payment documents or other primary documents. Article 720 of the Civil Code separately provides that the restriction in a company’s charter on gifts between business companies does not extend to a legal entity’s right to enter into a donation agreement.

Confirm the actual transfer of money, goods, and services

Under Article 9 of Law No. 996-XIV on Accounting, primary documents form the basis for recording a transaction. They must state the document name and date, the name of the enterprise on whose behalf it was drawn up, the content and scope of the transaction, the unit of measurement, and the signatures or other data identifying the transaction participants. The positions and surnames of responsible persons are also required, except in primary documents whose requirements are set by the National Bank of Ukraine.

Practical recommendation for payments. Use a clear payment reference, for example: “Charitable donation for purchasing food packages for beneficiaries under Agreement No. …”. A payment instruction that was created but not executed does not prove that money was transferred.

Practical recommendation for goods. List specific names, item codes where needed, quantities, units of measurement, unit values, and the total value in the certificate. For equipment, include serial numbers and condition. State which valuation is shown: the donor’s carrying value or another agreed valuation. Internal inventory write-off and the recipient’s acceptance substantiate different stages of the transaction, so retain both documents.

For services, specify a verifiable result: completed repairs with a list of work, transport of a specified shipment along a stated route, or a defined number of hours of particular services. Substantiate company expenses with documents for materials, labor costs, contractor services, and a corresponding cost calculation. The advertised price of a similar service does not replace the donor’s actual expenses.

Documents may be prepared on paper or electronically in accordance with electronic document management requirements. Under paragraph 1.4 of Regulation of the Ministry of Finance of Ukraine No. 88, primary documents and accounting registers must be prepared in Ukrainian. If a document from a foreign donor or supplier is in another language and the enterprise uses it for an accounting entry, arrange an accurate and authentic Ukrainian translation. Use a scan for routine exchange, and retain the original or a properly signed electronic document. The simplification under Article 9 of Law No. 996-XIV that allows certain customer details to be omitted from service documents does not apply to agreements for donations, charitable aid, or humanitarian aid.

Photos of the transfer, a thank-you letter, or a report on a social event may be added to the file. Accounting requires documents for the specific actual transaction: who transferred what, to whom, and when.

Separate the business’s own support from collecting customer donations

When a company transfers its own funds, it is the donor. When a store collects donations from an unspecified group of customers, Article 7 of Law No. 5073-VI on public fundraising applies. Before installing a donation box, determine on whose behalf and for whose benefit the funds will be collected.

• To collect on behalf of a charitable organization, the organization’s director must issue a notarized power of attorney.
• To collect in one’s own name for the benefit of a charitable organization, a charitable activity agreement with that organization is required.
• To collect on behalf of, or for the benefit of, another beneficiary, an agreement with that beneficiary or their legal representative is required.

The power of attorney or agreement must specify the purpose, place and duration of the collection, and how the donations will be used. For collections made on behalf of a charitable organization or in one’s own name for its benefit, the arrangements must also specify how the organization’s financial reports will be publicly accessible. Contractual arrangements must also set out the parties’ liability. For collections made on behalf of or for the benefit of other beneficiaries, the agreement must specify the intended use, accounting and reporting procedures, as well as the collector’s liability to the beneficiary and donors for breach of the agreement or donation-use procedures.

Collecting excisable goods is prohibited; for public fundraising to support military formations, the law also refers to the procedure established by the Cabinet of Ministers of Ukraine.

Practical recommendation for a donation box. Specify in the agreement who owns the box, who is responsible for installing and opening it, and how the cash will be counted and transferred. Document each withdrawal of cash with a certificate stating the box number, date, amount, and responsible persons’ signatures. Attach a document showing the organization’s acceptance of the money or a bank document confirming its transfer.

If the money belongs to a charitable organization or another beneficiary, do not keep it in the store’s cash desk: paragraph 38 of Regulation of the National Bank of Ukraine No. 148 prohibits an enterprise from keeping another party’s cash there, even separately from its own funds. Specify in the agreement who receives the collected cash, records its receipt, and transfers it to the recipient.

Account separately for the store’s own donation.

Under paragraphs 11, 25, 26, and 39 of Regulation of the National Bank of Ukraine No. 148, an enterprise records cash on the day it is received and in the full amount, prepares cash documents, and maintains a cash book. Deadlines for depositing cash and the cash limit depend on the established procedure. For an individual entrepreneur, no cash book, cash limit, or cash deposit deadlines are set. Cash settlement limits of UAH 10,000 and UAH 50,000 do not apply to voluntary donations and charitable aid; this is an exception under paragraph 8 of the Regulation.

Funds collected for others cannot automatically be treated as the individual entrepreneur’s own donation or business income merely because they passed through the entrepreneur. At the same time, labeling a payment “fundraising” does not secure a tax exemption. The documents must substantiate the legal arrangement, the collector’s authority, and the transfer of the entire amount collected. Subparagraph 165.1.54 of the TCU provides separate conditions for exemption of funds actually used for specified purposes and documented related expenses by individuals included in the Register of Volunteers.

How a company accounts for support under corporate income tax

The accountant first records the actual transaction under the applicable accounting standards. Under paragraphs 5–7 of National Accounting Regulation (Standard) 16 “Expenses”, expenses are recognized when assets decrease or liabilities increase, provided they can be reliably measured. Expenses that cannot be directly linked to the income of a particular period are recorded in the period in which they are incurred. The amount of support in goods is substantiated by accounting records and transfer documents.

Next, determine the tax adjustments. Under subparagraph 134.1.1 of the TCU, a taxpayer whose accounting income, excluding indirect taxes, did not exceed UAH 40 million in the last annual reporting period may decide not to apply tax differences, except for exceptions set by the Code. This decision may be made no more than once during a continuous series of years in which the criterion is met, and must be stated in the return for the first year of that series.

The decision remains in effect in subsequent years; if income exceeds UAH 40 million, the taxpayer applies all relevant differences for the year in which the threshold is exceeded. The adjustment under subparagraph 140.5.9 does not apply to a taxpayer that meets the income criterion and has lawfully opted not to apply the relevant tax differences. If the company applies the relevant differences, the accountant must review the accounting expenses under the rules below.

Standard 4% limit and temporary 8% limit

Subparagraph 140.5.9 of the TCU requires increasing the financial result by the amount of gratuitous support to nonprofit organizations that exceeds 4% of taxable profit for the previous reporting year. The recipient must be listed in the Register of Nonprofit Institutions and Organizations on the transfer date. This is an aggregate annual calculation of the relevant transfers, so it is not enough to check each donation separately.

Paragraph 72 of subsection 4 of Section XX of the TCU applies to reporting periods from 2025 through the end of the calendar year in which martial law is terminated or lifted. It allows the taxpayer not to make this adjustment within 8% of the previous year’s profit if more than 4% of that profit was transferred specifically to charitable organizations listed in the Register. Exactly 4% does not meet this condition.

Both the standard rule and paragraph 72 exclude associations of insurers whose membership is a legal condition for an insurer’s activities, and nonprofit sports organizations covered by subparagraph 140.5.14 of the TCU. The latter sets a separate 8% limit for children’s and youth sports schools, Olympic training centers, schools of higher sports excellence, physical culture and sports centers for people with disabilities, and sports federations in Olympic sports, provided they had registered nonprofit status on the transfer date.

Illustrative examples. Assume the company’s taxable profit for the previous year was UAH 1,000,000. The 4% limit is UAH 40,000 and the 8% limit is UAH 80,000. The company applies tax differences, recipients have the required status, and all transfers below fall under the general charitable calculation.

If the previous year’s profit was zero or a loss was reported, there is no positive limit for these ordinary transfers. A charitable purpose alone does not allow a taxpayer applying the relevant differences to retain the full amount as a tax expense. If the recipient does not have the required nonprofit status, a taxpayer applying tax differences must check subparagraph 140.5.10 of the TCU.

It requires increasing the financial result by the full amount of non-repayable financial assistance or the value of goods, work, or services provided free of charge to persons that are not corporate income taxpayers, except individuals who pay personal income tax (PIT). An adjustment is also required for assistance to a related corporate income taxpayer that declared a tax loss for the previous year, if the donor included the assistance in its accounting expenses, and for certain zero-rate taxpayers specified in that provision.

Thus, the absence of nonprofit status does not, by itself, mean that the same adjustment applies to every recipient.

Support for defense and other special transfers

Until martial law is terminated or lifted, subparagraph 69.6 of subsection 10 of Section XX of the TCU temporarily provides that the adjustment under subparagraph 140.5.9 does not apply to specified transfers. This deadline differs from the 8% limit, which applies until the end of the calendar year in which martial law is terminated or lifted. The rule covers money, special personal protective equipment, technical surveillance equipment, medicinal products and medical devices, hygiene products, food, clothing and equipment, and other goods, work, and services, subject to the conditions set by the rule.

The specified recipients include the Armed Forces of Ukraine, National Guard of Ukraine, Security Service of Ukraine, Foreign Intelligence Service of Ukraine, State Border Guard Service of Ukraine, Ministry of Internal Affairs of Ukraine, State Protection Department of Ukraine, State Service of Special Communications and Information Protection of Ukraine, other lawfully established military formations and their units, subdivisions, institutions, and organizations funded from the state budget. The rule also covers the designated civil protection authority, civil protection forces, public and municipal healthcare facilities, and relevant healthcare units of state administrations. For defense transfers, substantiate the purpose required by the provision; for humanitarian aid, comply with the special legislation.

Subparagraph 69.6 separately covers funds transferred to accounts opened by the National Bank of Ukraine for state authorities for specified defense, recovery, and humanitarian purposes. A transfer to an individual’s or foundation’s account must be assessed based on the status of the actual recipient, even if the fundraising was announced as being for defense.

Practical recommendation. Keep a separate list of transactions under subparagraph 69.6, with documents showing the recipient, subject, and purpose. For a transfer that meets this special provision, do not also calculate an increase under the standard 4% or 8% limit.

Check VAT before releasing goods

Subparagraph 197.1.15 of the TCU provides an exemption for the gratuitous supply of goods and services to duly established and registered charitable organizations, and for aid they provide to beneficiaries in accordance with the law. The condition is that there be no monetary, material, or other compensation. A direct transfer by an ordinary company of goods to an individual requires a separate assessment; the charitable nature of the transfer alone does not substantiate use of this exemption.

For goods received from Ukrainian donors as charitable assistance for the purposes of Article 3 of Law No. 5073-VI, the donor must apply the Ukrainian wording «Благодійна допомога. Продаж заборонено» (“Charitable assistance. Sale prohibited”) to the goods’ label, tag, or packaging. The text must be fully and clearly visible. Agree with the recipient on the goods’ intended use and distribution: legal entity beneficiaries must keep records of receipt, storage, distribution, and use. Selling labeled assistance for compensation results in the seizure and confiscation of goods or proceeds as provided by law.

The exemption under subparagraph 197.1.15 does not apply to excisable goods, securities other than endowments provided for in the provision, intangible assets, or goods and services for use in business activities. Fuel and other excisable goods must be checked under the separate rules that apply.

Even when a supply itself is VAT-exempt, the accountant must check compensating tax liabilities under paragraph 198.5 for goods, services, and non-current assets purchased with VAT and used in exempt transactions. For an ordinary taxable gratuitous transfer, paragraph 188.1 sets a minimum tax base: the purchase price for purchased goods and services, the ordinary price for self-produced goods and services, and the balance sheet residual value of non-current assets at the beginning of the relevant tax period.

If records of non-current assets are absent, the minimum tax base is determined using the ordinary price. Paragraph 188.1 also provides exceptions to the minimum-base rules. The application of paragraphs 188.1 and 198.5 must be determined based on the tax treatment of the specific transaction.

Special VAT rule during martial law

Paragraph 32-1 of subsection 2 of Section XX of the TCU temporarily establishes special rules for defense and other specified transfers during martial law or a state of emergency. In particular, goods purchased in taxable transactions and transferred into state or municipal ownership, including for the benefit of volunteer formations of territorial communities, or to other persons for Ukraine’s defense needs, are not considered to have been used in non-taxable or non-business transactions.

This paragraph also does not treat as supplies fully gratuitous transfers of goods and services to the recipients it expressly names: the defense authorities and military formations listed in it, the State Emergency Service of Ukraine, volunteer formations of territorial communities, designated civil protection authorities and forces, public and municipal healthcare facilities, and relevant healthcare units of state administrations. For the defense recipient group, the provision requires the transfer to be for defense, public safety, and state interests. Transactions taxable at the zero VAT rate are excluded. Paragraph 198.5 does not apply to transactions covered by paragraph 32-1.

Practical recommendation. Before shipping goods, add a short calculation to the file: recipient, subject, purpose, VAT rule, basis for applying it, and acceptance documents. Check the conditions of paragraph 32-1 and subparagraph 69.6 for corporate income tax separately.

What individual entrepreneurs and owners donating personal funds should consider

For an individual entrepreneur under the simplified tax system, spending personal funds on ordinary charitable support does not reduce business income. Documents are needed to substantiate the transfer and meet any other obligations that arise, including VAT or tax obligations on payments to individuals.

An individual entrepreneur under the general tax system calculates net taxable income under Article 177 of the TCU. Paragraph 177.4 lists expenses related to earning business income, while subparagraph 177.4.5 excludes expenses unrelated to business activity and undocumented expenses. An ordinary charitable donation does not become an allowable business expense simply because there is an agreement and payment document.

For a personal donation by an individual, subparagraph 166.3.2 of the TCU provides a tax deduction for money or property actually transferred to nonprofit organizations, up to 4% of the individual’s total taxable income for the reporting year. The recipient must meet the conditions of paragraph 133.4 on the transfer date. Subject to the limits established by Article 166, the deduction applies to salary income; it does not reduce business income.

Only an individual resident of Ukraine who has a taxpayer registration card number, or who has officially refused one on religious grounds, notified the supervisory authority, and has a corresponding passport notation, may claim the tax deduction. Keep documents identifying the personal donor and recipient, the amount or value, and proof of transfer. Submit copies of supporting documents with the return; for an electronic payment document, state its details in the return. The return claiming the deduction must be filed by December 31 inclusive of the year following the reporting year. Any unused entitlement does not carry forward to later years.

Support for individuals: choose an exemption basis and file the required reports

Paragraph 170.7 of the TCU distinguishes targeted assistance, which has conditions and permitted spending purposes, from non-targeted assistance, which has no such restrictions. Before payment, identify the specific tax basis because wording such as “for medical treatment” or “for an affected person” does not, by itself, satisfy all the conditions for exemption.

Non-targeted assistance: annual limit of UAH 4,660

Under subparagraph 170.7.3, the tax-free limit for ordinary non-targeted assistance from resident donors is cumulative for each recipient over the year. In 2026 it is UAH 4,660: the subsistence minimum for an able-bodied person of UAH 3,328 × 1.4 = UAH 4,659.20, rounded to the nearest UAH 10, equals UAH 4,660. The calculation is based on subparagraph 169.4.1 of the TCU and Article 7 of the Law on the State Budget of Ukraine for 2026 No. 4695-IX.

Under ordinary conditions, the taxable excess of cash assistance is subject to personal income tax (PIT) at 18% and military levy at 5%. If assistance is provided as goods, work, or services, the accountant must separately determine the taxable base for non-cash income and the tax payment procedure. Under subparagraph 1.3 of paragraph 16-1 of subsection 10 of Section XX of the TCU, the 5% military levy rate applies through the end of the third calendar year following the year in which martial law is terminated or lifted; from January 1 of the next year, the rate will be 1.5%.

Assistance that meets the conditions for a PIT exemption is also exempt from the military levy under subparagraph 1.7 of paragraph 16-1 of subsection 10 of Section XX of the TCU. It is therefore incorrect to charge 5% on all charitable assistance to individuals.

Illustrative cash example. A company accrues UAH 6,000 in non-targeted assistance to an individual. Assume the person received no other such assistance during the year and no special exemptions apply. The excess is UAH 6,000 − UAH 4,660 = UAH 1,340. PIT is UAH 1,340 × 18% = UAH 241.20; the military levy is UAH 1,340 × 5% = UAH 67. The amount payable after withholding these taxes is UAH 5,691.80. The recipient must file an annual return if total non-targeted assistance for the year exceeded the applicable limit.

Targeted assistance for medical treatment and other specified needs

Subparagraph 170.7.4 provides an exemption for targeted assistance from resident donors in Ukraine for specified purposes. In addition to medical treatment, it covers designated rehabilitation services and equipment; assistance for children through listed institutions and families; food and overnight accommodation for people without housing through specified providers; improving the living conditions of people in penitentiary institutions; and assistance through designated institutions for older people, people with disabilities, and other persons in their care.

Separate grounds are provided for open scientific research, amateur sports, tuition paid to an educational institution for specified categories of children and people with disabilities, and provision of rehabilitation equipment under the conditions of subparagraph “ж”. Before making a payment, check the applicable subparagraph: who the assistance must be paid to, which expenses may be covered, and what special conditions the beneficiary must meet. For example, a donor may pay a healthcare facility for treatment of individuals specified in the provision without a general cash limit, subject to the stated exceptions for procedures and expenses.

Subparagraph “a” also limits the exemption to expenses not covered by benefits from the mandatory state social health insurance fund; for rehabilitation services and equipment, coverage from budgets is also taken into account. Until this insurance system is introduced, the exemption applies to the total amount of assistance for the relevant purposes, subject to other established limits. In particular, the provision excludes certain cosmetic procedures, certain types of dental treatment, and other expressly specified expenses.

A separate cumulative annual limit of UAH 300,000 applies to assistance for specified families’ needs for children. Apply the part of the subparagraph that matches the recipient and need.

Under subparagraph 165.1.19 of the TCU, an employer or charitable organization may provide tax-exempt assistance for medical treatment and healthcare services for an individual, a first-degree family member, or a child under that individual’s custody or guardianship. For an employer, this applies to assistance for an employee, the employee’s first-degree family members, and a child under the employee’s custody or guardianship. If assistance is provided in monetary form, the expenses must be supported by documents. The exemption does not cover expenses reimbursed by benefits from the mandatory state social health insurance fund. Before payment, identify who is being treated, who is providing the assistance, and which documents substantiate the expenses.

Practical recommendation. For treatment payments, document the beneficiary, the relationship to them required by law, the healthcare provider, invoice, permitted need, and amount. After payment, retain proof of payment and documents showing the services provided or use of the funds. To substantiate an exemption, collect only the information needed; a full medical history should not be a standard requirement for every request.

Under subparagraph 170.7.5, the terms of targeted cash assistance set the period for its use, but generally it may not exceed 12 calendar months following the month of receipt. For medical treatment, the period may be up to 24 such months. The time limit under subparagraph 170.7.5 does not apply to assistance in the form of an endowment—funds or securities contributed by a donor to a financial institution, the interest or dividends from which are used by the beneficiary.

The beneficiary may not spend or dispose of the endowment principal without the donor’s consent. If unused funds are not returned by the end of the period, the recipient includes them in annual taxable income. Subparagraph 170.7.6 allows an application to the supervisory authority to extend the period, with an explanation of why the assistance could not be used on time.

Special assistance during martial law

Subparagraph 165.1.54 together with subparagraph 170.7.8 of the TCU provides an exemption for specified categories of defenders, their family members, engaged workers and civil protection forces, residents of settlements where hostilities are taking place, and people who were forced to leave such places of residence. For certain categories, direct participation in relevant measures and presence in the areas where they were carried out must be substantiated. Family membership is also determined by the conditions of the Code.

For the categories of defenders specified in subparagraph 170.7.8, assistance for specified protective and surveillance equipment, medicines, food, clothing and equipment, other goods on the government list, and relevant medical needs is exempt in any amount if its conditions are met. Assistance for medical treatment for other specified categories has its own list of permitted expenses. Assistance for property restoration and housing, social, household, and other needs on the government list is subject to an aggregate annual limit of 500 minimum wages as of January 1 of the year. In 2026 this is 500 × UAH 8,647 = UAH 4,323,500. Any taxable excess must be declared.

Subparagraph 170.7.2 of the TCU also provides an exemption for targeted and non-targeted assistance to people affected by environmental, technological, and other disasters in areas officially declared zones of environmental emergency, within amounts set by the Cabinet of Ministers of Ukraine. For people affected by natural disasters, accidents, epidemics, and epizootics, a decision by the Cabinet of Ministers of Ukraine or local self-government body to provide or mobilize assistance is required; the applicable limits are set by that authority.

Assistance under this rule is distributed through the state or local budget, or through charitable organizations or the Ukrainian Red Cross Society listed in the Register of Nonprofit Institutions and Organizations. Assistance for restoring lost property and meeting housing, social, household, and other needs on the government list must be provided in kind. Before applying the exemption, check the decision, applicable limit, and documents showing the circumstances that affected the beneficiary.

For people affected by armed aggression during martial law or a state of emergency, subparagraph 170.7.2 provides a separate exemption basis. Assistance is distributed through the state or local budget, or through charitable organizations or the Ukrainian Red Cross Society listed in the Register of Nonprofit Institutions and Organizations. Under this rule, assistance for restoring lost property and meeting housing, social, household, and other needs on the government list must be provided in kind. Before making a direct payment from a store, determine whether it qualifies under another specific exemption basis.

The exemption period for relevant assistance under subparagraph 165.1.54 runs through December 31 inclusive of the year following the year in which martial law or a state of emergency is terminated or lifted and/or the measures specified in that provision end. Documents must substantiate the beneficiary’s category, the permitted need, and the actual transfer or use of the assistance.

How to report payments in the tax calculation

Subparagraph 170.7.9 of the TCU requires a tax agent to report the amount of charitable assistance in the tax calculation, including when it is exempt from tax. Appendix 4DF is used for personalized information on income accrued to individuals and taxes withheld. Before making a payment, obtain the beneficiary’s necessary details and determine the income code based on the type of assistance.

Under Articles 51 and 176 of the TCU, legal entities acting as tax agents report monthly, while individual entrepreneurs and persons conducting independent professional activities report quarterly, broken down by month within the quarter. Under subparagraphs 49.18.1 and 49.18.2 of the TCU, a legal entity must file the calculation within 20 calendar days after the last calendar day of the reporting month, while an individual entrepreneur or person conducting independent professional activities must file it within 40 calendar days after the last calendar day of the reporting quarter.

If the filing deadline falls on a weekend or public holiday, paragraph 49.20 of the TCU moves it to the next business day. The calculation is filed when the relevant income was accrued during the reporting period. Reporting frequency does not change the deadlines for withholding and paying taxes on a payment.

If an assistance recipient must file an annual return because the tax-free limit was exceeded or targeted assistance remained unused and unreturned, they must file it before May 1 of the year following the reporting year under subparagraph 49.18.4 of the TCU. If the filing deadline falls on a weekend or public holiday, the extension under paragraph 49.20 of the TCU applies. The recipient’s obligation is separate from the donor’s filing of the tax calculation with Appendix 4DF.

Humanitarian shipments: documentation and reporting calendar

If a business participates in importing humanitarian aid, first identify the donor, the recipient responsible for the system and reporting, and the beneficiary to whom the aid will actually be transferred. Article 1 of Law No. 1192-XIV defines the categories of recipients and beneficiaries. Paragraph 3-1 of Article 15 allows certain persons specified by law to have recipient status during martial law and for three months after it is terminated or lifted, regardless of inclusion in the Unified Register.

However, importing under Procedure No. 953 requires registration details and actions in the automated system. If the recipient purchased the aid abroad, paragraph 3-7 of Article 15 of Law No. 1192-XIV also applies: during martial law and for three months after it is terminated or lifted, purchased goods, work, or services qualify as humanitarian aid if they are declared upon import and transferred free of charge to beneficiaries defined in Article 1 of the Law within six months.

Plan the transfer deadline for such a shipment separately from the monthly reporting deadlines.

The general procedure for imports during martial law is established by Resolution of the Cabinet of Ministers of Ukraine dated September 5, 2023 No. 953. For an ordinary shipment processed under this Procedure, follow these steps:

1. Obtain the donor’s written offer and the recipient’s written consent, and specify the aid’s contents and intended purpose.
2. Register the recipient in the Unified Register through the automated system and obtain its number.
3. Before declaration, enter the list of goods into the system and obtain a unique humanitarian aid code.
4. Prepare and submit the declaration. It may be submitted electronically or on paper as provided by the procedure, but submission without a unique code is not allowed. Match the names, categories, number of packages, units, and weight or volume to the system data.
5. After receipt, check the actual shipment, record it and prepare an inventory description, and substantiate each transfer to beneficiaries with primary documents.
6. Submit a report for the relevant month and continue reporting until all aid has been distributed.

If the final day for submitting a report falls on a weekend or holiday, paragraph 12 of the Procedure moves it to the next working day. Healthcare facilities authorized by the Ministry of Health of Ukraine to receive specified medical humanitarian aid follow a special procedure: the inventory description is submitted no later than 60 calendar days from the relevant customs clearance information date through the MedData system; reports are also submitted through it by automated data exchange.

90 days is not permission to postpone monthly reporting. Under paragraph 13, declared aid for which no report is submitted within 90 calendar days from the date customs clearance information is entered is treated as unaccounted for in terms of receipt and intended use, and as used for an unintended purpose.

Paragraph 14 provides for account blocking and loss of status if a report is not submitted within 90 days from the customs clearance date or if an up-to-date report on balances is missing for 90 consecutive days. This rule has an exception for budget enterprises, institutions, and organizations, state institutions authorized by them, and local self-government bodies. For a first violation, status is lost for three months; if a report is submitted within a month after blocking, the administrator unblocks the account within ten calendar days. For a repeated violation, re-registration is possible no earlier than six months later.

Practical recommendation. Before shipment, assign one person to the system and another to warehouse and transfer documents. Keep a table for each declaration with the code, customs clearance date, date information was entered, actual quantity, amount transferred, balance, and next report. Procedure No. 953 has separate rules for vehicles and special categories of goods, so the ordinary shipment procedure does not replace checking those conditions.

Checking warehouse balances and recording charitable payments in Torgsoft

Before transferring inventory, use Torgsoft’s “Склад → Стан складу” (Warehouse → Stock Status) mode to check names, quantities, units of measurement, and cost. The “Стан на дату” (Status as of date) filter lets you view quantities on a selected date, and stock movements help reconcile warehouse transactions. It is practical to compare these data with the issue or write-off and the signed assistance certificate. Check the cost figure in light of the configured costing method and accounting documents.

The “Фінансовий документ” (Financial Document) mode supports recording cash and bank transactions, selecting a counterparty and enterprise, choosing a financial analysis category, and specifying a payment purpose. To track the business’s own assistance, you can use a separate analysis category and reconcile transactions against bank statements and certificates. The separate “Платіжне доручення” (Payment Order) tab is available when the “Банківські виписки за рахунками” (Bank Statements by Account) option is activated. The accountant determines the tax exemption basis, profit adjustment, and required reporting from the documents and law; an entry in the software does not, by itself, substantiate them.

Retain documents and check that the transaction is complete

Under paragraph 44.3 of the TCU, the minimum retention period for primary documents, accounting registers, financial statements, and other tax documents of legal entities specified in that paragraph, including entities under the simplified tax system, is generally 1,825 days. A period of 1,095 days applies to other documents not covered by special categories. Documents subject to special tax oversight may have a longer period.

For documents used in reporting, the period is counted from the date the return is filed, or from its filing deadline if it is not filed. Extensions of deadlines must also be taken into account in the cases provided for by the Code. Documents relating to an audit or dispute must be retained until the relevant procedures are complete, and for at least the applicable minimum period.

Paragraph 121.1 of the TCU provides for a UAH 1,020 fine for failure to ensure document retention for the prescribed periods and/or failure to provide originals or copies during tax oversight in cases specified by the Code. For the same actions by a taxpayer already fined for the same violation during the year, the fine is UAH 2,040. Separately from the fine, missing supporting documents may affect whether reported figures are accepted.

The company must also retain primary documents for charitable assistance for at least five calendar years under the List of Standard Documents approved by Order of the Ministry of Justice of Ukraine dated April 12, 2012 No. 578/5. Because leap days can make five years and 1,825 days end on different dates, the company must meet both applicable retention periods, taking any extensions into account.

For documents concerning an audit or appeal, the List’s notes also apply: retain them at least for the prescribed minimum period and for one year after the period for judicial appeal of the decision expires; if the decision is appealed, retain them for one year after the court decision concluding the case becomes legally effective, and, if further appealed, for three months after the final court decision becomes legally effective.

These requirements apply equally to paper and electronic documents. For an individual entrepreneur’s tax documents, paragraph 1.4 of the List refers separately to the TCU, so determine the retention period under the relevant tax provisions, taking extensions and disputes into account.

If documents are lost, damaged, or destroyed prematurely, paragraph 44.5 requires written notice to the relevant supervisory authority within five days, with evidence of the event, and restoration of the documents within 90 calendar days from the day after the authority receives the notice. If the documents relate to customs clearance, the relevant customs authority must also be notified. If primary documents, registers, or reports are lost or destroyed, the enterprise’s director must also notify law enforcement authorities in writing and appoint a commission by order to identify the missing documents and cause of the event.

Under paragraph 6.10 of Regulation of the Ministry of Finance of Ukraine No. 88, the commission records its findings in an act approved by the director; the enterprise sends a copy to the bodies specified in that paragraph within ten days.

Practical check before closing the file:

• The purpose, subject, recipient, and recipient’s status match the legal and tax rule being applied.
• The bank completed the transfer, or an authorized recipient confirmed acceptance of the cash, goods, work, or services.
• Warehouse quantities and values reconcile with the transfer documents and expense records.
• The accountant separately checked corporate income tax, VAT, and tax agent obligations for individuals.
• For targeted assistance, a use deadline and receipt of a report are specified; for humanitarian aid, the required reports on distribution and balances have been submitted.
• The file contains originals or properly executed electronic documents, registry evidence, and calculations of the tax conditions applied.

Official sources for documenting and checking the transaction

• Order of the Ministry of Justice of Ukraine dated April 12, 2012 No. 578/5 “On Approval of the List of Standard Documents Created in the Activities of State Authorities, Local Self-Government Bodies, and Other Legal Entities, Specifying Document Retention Periods” — paragraphs 1.4, 1.7, 1.8, 2.10, and 2.11 of the List and the row “Primary documents and their attachments recording the performance of business transactions and serving as the basis for entries in accounting registers and tax documents”: scope, minimum retention periods, electronic documents, when retention periods begin, and conditions for extending retention.
• Law of Ukraine dated July 5, 2012 No. 5073-VI “On Charitable Activities and Charitable Organizations” — Articles 1, 3–7, and 17: participants, purposes, donations, public fundraising, and reports to donors.
• Civil Code of Ukraine No. 435-IV — Articles 206–208, 719, 720, 729, and 730: oral and written forms of transactions, the form of gift agreements, parties, acceptance of donations, and use controls.
• Law of Ukraine No. 996-XIV “On Accounting and Financial Reporting in Ukraine” — Article 9: primary documents and their details.
• Order of the Ministry of Finance of Ukraine dated May 24, 1995 No. 88 “On Approval of the Regulation on Documentary Support for Accounting Entries” — paragraphs 1.4 and 2.4, Sections 2, 5, and 6: documentation, recipient authority, document flow, and retention.
• National Accounting Regulation (Standard) 16 “Expenses,” Order No. 318 — paragraphs 5–9, 20, and 29: recognition and composition of expenses.
• Tax Code of Ukraine No. 2755-VI — Articles 44, 49, 51, and 121; subparagraphs 134.1.1, 140.5.9, 140.5.10, 140.5.14, 165.1.19, 165.1.54, 166.3.2, and 169.4.1; paragraph 170.7; Articles 176 and 177; paragraphs 188.1 and 198.5; subparagraph 197.1.15; paragraph 32-1 of subsection 2, paragraph 72 of subsection 4, paragraphs 16-1 and 69.6 of subsection 10, and paragraph 5 of subsection 1 of Section XX.
• Law of Ukraine No. 4695-IX “On the State Budget of Ukraine for 2026” — Articles 7 and 8: indicators used to calculate annual assistance limits.
• Resolution of the Board of the National Bank of Ukraine dated December 29, 2017 No. 148 “On Approval of the Regulation on Cash Transactions in the National Currency of Ukraine” — paragraphs 8, 11, 14, 23–29, 38, 39, and 48–50: cash donations, cash documents, and deadlines for depositing cash.
• Law of Ukraine dated October 22, 1999 No. 1192-XIV “On Humanitarian Aid” — Articles 1, 3, 6, 8, 11, 12, and 15: participants, special regime, accounting, and temporary rules.
• Resolution of the Cabinet of Ministers of Ukraine dated September 5, 2023 No. 953 “Certain Issues of the Passage and Accounting of Humanitarian Aid under Martial Law” — paragraphs 1–14 of the Procedure: registration, declarations, inventory descriptions, reporting, and consequences of missed deadlines.