The Ministry of Finance's new "tax package" for retail and individual entrepreneurs: VAT, marketplaces, military levy, parcels

Ministry of Finance Tax Initiatives in Spring 2026: what is already in force, what is only proposed, and what entrepreneurs should prepare for

As of March 23, 2026, it is important for businesses to distinguish between current law and draft amendments. 

Several separate documents have been published on the website of the Ministry of Finance: 

• March 19, 2026 — a draft law on digital platforms, e-commerce, and VAT; 

• February 24, 2026 — the ATAD draft on combating tax avoidance; 

• March 4, 2026 — a draft order on amendments to the corporate income tax return form; 

• March 18, 2026 — a draft order on amendments to the registration of individuals in the State Register of Individual Taxpayers. 

Separately, it should be taken into account that the previous draft law No. 14025 was not adopted by the Verkhovna Rada on March 10, 2026, and was removed from consideration. 

What rules are in force now?

Mandatory VAT registration under the general rule remains tied to the threshold of UAH 1,000,000 in taxable transactions over the last 12 calendar months. At the same time, current paragraph 181.1 of the Tax Code provides an exception for single tax payers of groups 1 through 3. That means that as of March 23, 2026, Sole Proprietorships and legal entities on the simplified system do not automatically move to VAT simply because they reach UAH 4 million — such a rule does not yet exist in the current Code.

The military levy for the simplified tax system is already in force in the amounts that businesses discuss as “new.” 

• For Sole Proprietorships — single tax payers in groups 1, 2, and 4, it amounts to 10% of the monthly minimum wage; 

• for single tax payers in group 3 — 1% of income; 

• the general levy rate for taxpayers specified by law is 5% of the taxable base. 

Since the minimum wage from January 1, 2026, is set at UAH 8,647, for Sole Proprietorships in groups 1, 2, and 4 the actual amount of the levy in 2026 is UAH 864.70 per month.

The exemption for international parcels up to EUR 150 is currently in force. Under Article 234 of the Customs Code, goods sent to a citizen in international postal or express shipments, if their total invoice value does not exceed the equivalent of EUR 150, are not subject to customs duties. Therefore, the claim that this exemption has already been abolished does not correspond to current law as of March 23, 2026.

The Ministry of Finance draft of March 19, 2026: digital platforms, e-commerce, and VAT

Mandatory VAT for some simplified tax system taxpayers

The draft published by the Ministry of Finance does indeed propose raising the threshold for mandatory VAT registration to UAH 4,000,000 excluding VAT and extending this requirement to single tax payers — legal entities and Sole Proprietorships, except for single tax payers of group 3 who are electronic residents. 

The draft also expressly provides for automatic registration based on tax reporting data with the registration date of January 1, 2027, if the excess is confirmed by declarations for 2025 and reporting for Q4 2025 and Q1–Q3 2026. If it becomes clear in Q1 2027 that there were no grounds for such registration, the draft allows it to be automatically canceled from the registration date.

The draft also changes the VAT reporting regime for simplified tax system taxpayers who become VAT payers. For them, the reporting tax period is proposed to be a calendar quarter. If such a taxpayer moves from the simplified system to other taxes and levies, they must return to a monthly VAT period from the first month of the transition. Separately, the draft allows, when supplying goods or services to non-VAT payers, as well as when receiving advance payment from them, the issuance of consolidated tax invoices no later than the last day of the month, taking into account the total volume of such transactions.

The preferential UAH 1 penalty is included in the draft, but its scope is much narrower than is often presented in publications. It applies to the first five violations committed during Q2–Q4 2027 by single tax payers who become VAT payers under the new rules. These are sanctions provided for by paragraph 120.1, paragraph 1201.1, paragraph 123.1, and paragraph 124.1 of the Tax Code of Ukraine. Therefore, this is not a “penalty-free 2027” and not a universal amnesty for all VAT errors.

Income through digital platforms

The draft published on March 19, 2026, introduces a separate set of rules for the international automatic exchange of information on income received through digital platforms and for the taxation of individuals who sell goods or provide services through such services. The first reporting period for platform operators is defined in the draft as 2027, and the first report in 2028 must be submitted no earlier than January 31, 2028. By January 1, 2027, reporting platform operators and excluded platform operators must register; some of the provisions on the exchange of information itself are to start from November 1, 2026, but not earlier than Ukraine’s accession to the Multilateral Competent Authority Agreement on DPI.

Under the draft, platform operators are required to submit to the controlling authority, by January 31 each year, a report on the income of reportable sellers. Before filing such a report, they must carry out due diligence on sellers and collect a specified scope of identification information. For individuals, this includes, in particular, surname, first name, patronymic, primary residential address, tax number, and, where applicable, individual VAT payer number, as well as date of birth. For organizations — name, address, tax number, registration number, and data on a permanent establishment, if any.

For resident individuals, the draft provides a separate preferential taxation regime for income from reportable activities through platforms at a rate of 5%, but only if all the established conditions are met simultaneously. These include: age 18+, at least one account with a Ukrainian bank reported to each platform operator, settlements exclusively in cashless form through such an account, no sanctions, no self-employed status, no employees, annual income of no more than 834 minimum wages as of January 1 of the reporting year, and no sale of excisable goods.

The draft does indeed contain a tax-free threshold of EUR 2,000 for the sale of goods through platforms. If the aggregate income of an individual from the sale of goods through platforms during a calendar year does not exceed the equivalent of EUR 2,000, such income is not considered taxable. For this case, the draft also provides a relaxation regarding the account: there is no need to open a separate current account for reportable activity, and it is allowed to use an existing account opened for personal needs, but its details must be reported to the platform operator.

If income from the sale of goods exceeds EUR 2,000 and such income is received through two or more platforms, the draft imposes on the individual the obligation to reflect the excess amount in the annual declaration of property status and income and to independently pay tax on the excess amount. If the seller does not report the account to the operator in the manner предусмотрен by the draft, the general rate defined by paragraph 167.1 of the Tax Code of Ukraine will apply rather than the preferential regime.

The draft provides separate penalties for platform operators. Failure to submit a report — 100 minimum wages; late submission — 0.5 of the minimum wage for each day of delay; submission of incomplete, inaccurate, or erroneous information — 0.5 of the minimum wage for each seller with respect to whom an error is found. Separately, the draft provides for increased liability for violations of the due diligence rules.

International parcels and distance selling of goods

The March 19, 2026 draft does not simply concern the “abolition of EUR 150,” but rather a different model for the taxation of distance sales of imported goods. The draft adds a separate taxable object for the supply of non-excisable goods with a total invoice value up to the equivalent of EUR 150, if they are imported into Ukraine under the rules for distance selling of goods and purchased through an electronic interface. At the same time, the draft exempts from taxation the very operation of importing into the customs territory of Ukraine non-excisable goods purchased under the rules of distance selling to an individual, and defines the date when the tax liability arises under this model as the date when funds are received by the electronic interface enterprise.

That means that as of March 2026, the correct way to put it is this: the current exemption up to EUR 150 has not been abolished, but the Ministry of Finance proposes from 2027 to switch to a separate VAT regime for the distance sale of imported low-value goods. For businesses, this means a potential change not only in the amount of tax, but in the entire chain — from pricing and contracts with platforms to customs declaration, accounting, and determining the moment when the tax liability arises.

The EUR 45 exception is also included in the draft, but it is not a universal exemption for any online purchase. The draft exempts from taxation the import of goods up to the equivalent of EUR 45 only when they are sent by an individual sender to an individual recipient without any payment, are intended for personal or family use, and by their characteristics and quantity have no commercial purpose.

The military levy in the Ministry of Finance March package

In this part, the published Ministry of Finance package does not create new levy rates for businesses, but proposes a different duration for the already established rules. In the explanatory note to the draft dated March 19, 2026, the Ministry of Finance expressly states that it is about extending the current military levy rates until the decision of the Verkhovna Rada of Ukraine on completing the reform of the Armed Forces of Ukraine enters into force. For individuals, the explanatory materials mention a rate of 5%; for Sole Proprietorships — single tax payers in groups 1, 2, and 4 — 10% of one minimum wage; for single tax payers in group 3 — 1% of income. For business practice, this means that the novelty here lies primarily not in the amount, but in the proposed duration of this regime.

The Ministry of Finance ATAD draft of February 24, 2026

Separately, on February 24, 2026, the Ministry of Finance submitted for public discussion a draft law on the implementation of anti-tax avoidance rules in accordance with Council Directive (EU) 2016/1164. This is a different document and is not identical to the draft of March 19, 2026. In its official materials, the Ministry of Finance expressly calls it a European integration draft and states that it is aimed at aligning Ukrainian tax legislation with ATAD I and ATAD II.

According to the official description of the Ministry of Finance, this draft provides for at least three major blocks. The first is the limitation on interest deductibility: excessive borrowing costs are proposed to be deductible only within 30% of EBITDA. The second is exit tax: taxation of capital gains in cases of a change of tax residence, transfer of assets or activity outside Ukraine, or transfer of property to a permanent establishment abroad. The third is the rules on hybrid mismatches, which are intended to neutralize situations where the same expense is deducted twice or an expense is recognized without taxation of the corresponding income.

The text of the draft also significantly strengthens the instruments for controlling international structures. It introduces new rules on “tax abuse,” criteria for the place of effective management of a foreign legal entity or a foreign arrangement without legal personality, as well as separate rules for registering such persons and liability for violations of registration rules. In particular, the published draft includes a fine of UAH 600,000 for a non-resident for certain violations related to operating without proper registration.

For non-residents and international groups, procedural requirements are also important. The draft provides for the submission of an application and documents for registration, and for certain foreign arrangements — legalized documents and a notarized translation into Ukrainian. This issue does not concern mass small business, but it directly affects structures with a foreign element, holdings, trusts, partnerships, foreign SPVs, and companies that are effectively managed from Ukraine.

Changes to the corporate income tax return form

On March 4, 2026, the Ministry of Finance published a separate draft order on amendments to the Corporate Income Tax Return form. This is not yet an effective order, but specifically a draft for discussion. The most noticeable point in practice is a technical correction in Annex MPZ-Z: the draft clarifies that the amount of the minimum tax liability must be at least UAH 1,400 per 1 hectare if the share of arable land is at least 50%, and at least UAH 700 per 1 hectare if the share of arable land is less than 50%. In other words, the draft form brings the table into line with the already effective provisions of the Tax Code and the new declarations for single tax payers.

Practical conclusion for entrepreneurs

As of March 23, 2026, entrepreneurs should not apply these proposals as current law. What actually remains in force are the current rules of the Tax Code and the Customs Code: the current military levy, the current EUR 150 threshold for parcels, and the current VAT threshold of UAH 1 million, with an exception for single tax payers in groups 1–3. At the same time, it is already advisable to assess turnover for 2025–2026, set up primary accounting records, review working models with platforms and bank accounts, and for companies dealing with non-residents — separately monitor the ATAD block, since it is this block that may significantly change the rules for international structures and transfer pricing.

Official Sources

• Tax Code of Ukraine, Law No. 2755-VI — specifically Articles 181, 183, 186, 190, 201, 202, 292, Section 10 of Chapter XX.

• Customs Code of Ukraine, Law No. 4495-VI — specifically Articles 234, 236, 374 regarding international postal and express shipments.

• Law of Ukraine from 10.10.2024 No. 4015-IX — amendments regarding the military levy.

• Law of Ukraine from 04.12.2024 No. 4113-IX — amendments related to the digital economy and related tax norms.

• Law of Ukraine “On the State Budget of Ukraine for 2026”, No. 4695-IX — Article 8, minimum wage 8,647 UAH from 01.01.2026.

• Law of Ukraine “On the Application of Cash Registers in Retail, Catering and Service Sectors”, No. 265/95-VR.

• Ministry of Finance of Ukraine, section “Draft Regulatory Acts in 2026” — 19.03.2026 draft on digital platforms, e-commerce, and VAT; 24.02.2026 ATAD draft; 04.03.2026 draft changes to the profit tax return form; 18.03.2026 draft changes to the Regulation on the Registration of Individuals in the State Register of Taxpayers.

• Draft Law of 18.03.2026 “On Amendments to the Tax Code of Ukraine and the Law of Ukraine “On Banks and Banking Activities” regarding the introduction of international automatic information exchange on income received through digital platforms, taxation of e-commerce transactions, and ensuring equality of taxpayers in VAT taxation.”

• Explanatory Note to the Project of 19.03.2026 — regarding the military levy, the 4 million UAH threshold, and distance selling.

• Ministry of Finance: “Ministry of Finance invites to public discussion of the draft law on implementing rules to combat tax evasion (ATAD)” from 24.02.2026.

• Draft Bill No. 14025 on the Verkhovna Rada of Ukraine website — Status: rejected and removed from consideration on 10.03.2026.