Form No. 20-OPP: How to Report a Store, Lease, Move, and Closure

An individual entrepreneur (FOP) or legal entity that opens a store, leases a warehouse, or uses another property in its business must report it to the tax authority at its primary place of tax registration. To do so, it submits a Form No. 20-OPP statement within 10 working days after the property is registered, created, or opened. The requirement covers property that the taxpayer owns, leases, or leases out, and applies regardless of whether the taxpayer uses the general or simplified tax system.

Before filing, gather the documents for the premises, check the properties already registered in the Electronic Cabinet, and complete the statement’s 17 fields. Select indicator “1” for a new property, “3” to change details, and “6” to close a property. Separately specify the property’s actual status and the type of right held over it. After submitting, check the receipts and confirm that the details appear in the cabinet, especially if you plan to register software-based cash registers afterward.

Who files Form No. 20-OPP and which properties must be reported

For entrepreneurs and companies in Ukraine, this requirement is established by Clause 63.3 of the Tax Code of Ukraine and Section VIII of the Procedure for Taxpayer and Fee Payer Accounting, approved by Order No. 1588 of the Ministry of Finance of Ukraine. Taxpayers must report taxable property, property related to taxation, and property through which they conduct business. Therefore, having no sales revenue at a new store is not, by itself, a reason to delay filing.

Retail businesses should first check for these types of property:

• an owned or leased store, kiosk, or retail pavilion;
• a warehouse, office, or premises used to assemble and hand over orders;
• a land plot and the real estate located on it;
• vehicles used in the business;
• premises and other property that the entrepreneur or company leases to others.

The tenant and the owner each meet their reporting obligations separately. Even if the owner has already reported the premises, the tenant must still file its own statement about the property it leases. The owner reports their ownership right and the property’s actual status; the tenant reports their contractual right to use it and the status of the leased property.

If a company has separate subdivisions, they report property on their own balance sheets. The legal entity reports its remaining property, except for property already reported by its separate subdivisions. This rule under Clause 8.2 of Procedure No. 1588 helps prevent duplicate reporting.

Should you file a statement for your home address?

An entrepreneur’s registered home address does not, by itself, mean that every residence must be listed on Form No. 20-OPP. To decide, check whether the particular residence is property through which business is actually conducted or property related to taxation.

For example, if an entrepreneur stores goods and assembles orders at home, this use should be considered when identifying property to include in the statement. If the home is only a residential address, do not automatically treat it as a store or warehouse. A useful practical step is to write down which operations take place at each address, then identify the reportable property based on that description.

What should an online store report?

Selling through a website does not remove the requirement to report the actual business premises. Identify where the entrepreneur stores goods, processes orders, assembles parcels, and hands over purchases. Depending on how the business operates, these may be a warehouse, office, store, or other premises actually used in the business.

If you are registering a software-based registrar of settlement transactions (PRRO), first check that the relevant business unit is recorded under Form No. 20-OPP. Make sure the name and address in the PRRO registration statement match the accounting details for that property. A website address alone is not enough to describe the location of premises.

When can multiple properties be combined in one row?

Clause 8.4 of Procedure No. 1588 allows taxpayers to consolidate information. For example, if an office, warehouse, and warehouse-store are located in the same office center at one address, you may report them under a single property type and list the relevant parts in the name field.

Consolidation does not apply to movable or immovable property that must be state-registered and assigned a separate registration number. For example, list a land plot and the non-residential building on it separately. A shared address does not remove this restriction.

Vehicles are subject to a special rule. You may report the same type of vehicle as a group if the vehicles are identical in type, use, status, and type of right. They must not be mobile retail or food-service outlets, or mobile service outlets other than those providing passenger or freight transportation. In that case, select the type “motor vehicles” and enter the number of vehicles in the registration number field.

Practical recommendation: before combining properties, check the address and documents for each one. List separately any property that must be state-registered and assigned a separate number. The exception is a group of identical motor vehicles that meets the consolidation conditions above.

How to determine the filing deadline and tax authority

Under Clause 8.4 of Procedure No. 1588, you must file the statement within 10 working days after the property is registered, created, or opened. Under Clause 8.5, the same procedure and deadline apply when the property’s type, name, location, type of right, or status changes. Do not wait until your next tax return to report a change.

For leased premises, compare the lease agreement with the handover document: together, they should show when the tenant received the property for use. As a practical step, record the event, date, and deadline in your work calendar right away, and keep the document you relied on to determine them.

File Form No. 20-OPP with the tax authority at the taxpayer’s primary place of tax registration, even if the store is in another town or city. If a property is opened in an area where the taxpayer is not yet registered but must register at a non-primary place of tax accounting, you can address this by marking field 16 as appropriate.

The difference between the entrepreneur’s home address and the store’s address is not, by itself, a sufficient reason to add this mark. First check which tax authority keeps the property’s records and whether you are already registered there.

For electronic filing, take Clause 63.14 of the Tax Code of Ukraine into account: if the document is received after 4:00 p.m. on a working operating day, it is considered received on the next working operating day. As a practical precaution, submit the statement early enough to leave time to correct a possible rejection.

How to complete all 17 fields of Form No. 20-OPP

Use the form in Appendix 10 to Procedure No. 1588 and its instructions. In the top section, enter the tax authority, tax number, and the company name or, for an entrepreneur, their surname, first name, and patronymic if available. Only individuals whose passports bear the mark specified by the form may use passport details instead of a tax number.

When filing for the first time, list all property that must be reported. In later statements, include new property and property whose details are changing. Do not submit the completion instructions to the tax authority with the statement.

How to create and retain an identifier

The identifier in field 5 combines the property type code from the list with the taxpayer’s five-digit internal number. The form instructions give these examples: 24700001 for a cafe, where 247 is the type code and 00001 is the internal number; 00200010 for a kiosk, where 002 is the type code and 00010 is the internal number. Do not use these examples for a store with a different type.

Practical recommendation: keep your own property list with the type, identifier, address, and filing dates. Do not create a new identifier every time the name or status of the same property changes. A separate rule applies when the property’s purpose changes or it is repurposed: in that case, the Procedure expressly requires the identifier to change.

How to distinguish the submission indicator, status, and right

These fields answer different questions. Field 2 shows what you are reporting: new property, a change, or closure. Field 14 describes the property’s status. Field 15 shows the legal basis on which the taxpayer possesses or uses it.

Field 14 has the following values under the form instructions:

• 1 — under construction or being prepared for commissioning;
• 2 — in operation;
• 3 — temporarily not in operation;
• 5 — unfit for operation;
• 6 — property disposed of or returned to its owner;
• 7 — change of purpose or repurposing;
• 8 — leased;
• 9 — leased out.

In field 15, enter: 1 — ownership right; 2 — possession right; 3 — right of use in the form of an easement, emphyteusis, or superficies; 4 — right of economic management; 5 — right of operational management; 6 — right of permanent use; 7 — right of long-term use or lease; 8 — right of short-term use, lease, or hiring; 9 — mortgage; 10 — trust management of property.

For example, for a newly leased store, enter “1” in field 2, “8” in field 14, and select “7” or “8” in field 15 according to the legal basis and terms of use. The number “8” in the status field does not automatically determine the right code in the adjacent field.

How to file through the Electronic Cabinet

1. Check existing details. In the private section of the Electronic Cabinet, review taxable property and non-primary places of tax accounting. Clause 8.8 of Procedure No. 1588 provides for this option.
2. Prepare your documents. Gather the agreement, handover document, documents establishing the right and address, and the property’s registration number, if applicable.
3. Create Form No. 20-OPP. Check the primary place of tax accounting, taxpayer details, and the number of fields in the form. Add rows for new, changed, or closed property.
4. Check the details. Pay particular attention to the identifier, address, status, and type of right. If non-primary registration is required, check field 16.
5. Sign and submit. The entrepreneur signs the statement with their own qualified electronic signature (KEP). An authorized representative uses their own signature within the scope of properly documented authority. Do not give them the entrepreneur’s personal key.
6. Read the receipts. Save the submitted statement and all receipts you receive. Check the document’s acceptance result.
7. Check the registered property. After processing, confirm that the cabinet shows the correct address, identifier, status, and right.

Under Clause 8.6 of Procedure No. 1588, details from an electronic statement are entered no later than the day after it is received; details from a paper statement are entered no later than 10 working days from the date of receipt. If the statement is rejected, do not treat the obligation as fulfilled: correct the reason for rejection, resubmit the document, and check that it has been accepted.

For property registered by a state authority without assignment of a registration number, Clause 8.4 provides a separate procedure: submit a paper statement to the tax authority at your primary place of tax registration, together with a copy of the registration document. Leave the property’s registration number field blank; on the 17-field form, this is field 17.

What to do if the store is leased

Illustrative example. An entrepreneur receives premises under a short-term lease to open a store. The premises have not previously appeared in their accounting details.

1. The entrepreneur checks the agreement and handover document, identifies the date they received the premises, and determines the filing deadline.
2. Based on the actual purpose, they choose a property type, assign an internal number, and create an identifier.
3. They enter “1” in field 2, “8 — leased” in field 14, and “8 — right of short-term use, lease, or hiring” in field 15.
4. They enter the address in fields 6–13, provide the real property registration number if applicable, and check whether non-primary registration is needed.
5. They submit the statement, save the receipts, and check the property in the cabinet. They then use the matching business unit details to register PRRO.

If the owner has already reported this property and has now leased it out, the owner submits a change to their own details: indicator “3,” status “9 — leased out,” and ownership right “1.” The fact that the property has been leased does not mean the owner must close it in their records.

After the lease ends, each party assesses its own situation again. A tenant who returns the premises and no longer uses them reports closure of its property with indicator “6” and status “6 — property disposed of/returned to the owner.” The owner reports a change in status based on how the property will be used going forward.

How to report a store move

First determine what happened: did the address details for the same property change, or did you stop using one set of premises and obtain another? The answer determines how to complete the statement.

If the location details of the same property change, submit a row with indicator “3” and the new address. Clause 8.5 of Procedure No. 1588 provides for reporting a change of location. Returning one set of leased premises and taking possession of another requires reporting two different properties.

Illustrative example of a move between leased premises. An entrepreneur returns a store at one address to its owner and leases a store at another address.

1. Prepare PRRO before closing the old property. If you use a software cash register, before filing the property closure statement, send all created settlement documents to the fiscal server, including documents created in offline mode; receive confirmation of their delivery; submit the final fiscal report receipt; and close the shift. Reporting the property’s closure triggers automatic cancellation of the PRRO registration.
2. Record the return of the first premises. Prepare a row with its existing identifier, indicator “6,” and status “6.”
3. Record receipt of the new premises. Prepare a separate row with indicator “1,” a new identifier, the new address, status “8,” and the relevant type of right.
4. Meet the deadline for each event. If you include both rows in one statement, file it within the deadline for reporting each change.
5. Check acceptance and accounting. Confirm that the first property is closed and the new one appears with the correct details.
6. Register PRRO for the new store. In the Electronic Cabinet, check the notification of automatic cancellation of the previous registration. After the new property is recorded, submit Form No. 1-PRRO to register a cash register with the new store’s details. Begin processing transactions after registration is confirmed.

How to coordinate Form No. 20-OPP with PRRO registration

Under Clause 6, Section II of the Procedure for PRRO Registration, approved by Order No. 317 of the Ministry of Finance of Ukraine, registration is refused if the taxpayer has not reported the business unit, if the relevant property is closed or not in operation, or if discrepancies with the accounting details are found. Therefore, before submitting Form No. 1-PRRO, check not only that Form No. 20-OPP was filed, but also the result of its processing.

A change in the business unit’s name or address requires PRRO re-registration. Before submitting the relevant statement, you must submit the final fiscal report receipt and close the last shift. After the change is recorded, issue settlement documents with the new details. PRRO may be used only at a business unit whose details are entered in its register.

Reporting property as closed or not in operation has a separate consequence: Clause 3, Section III of this Procedure provides for automatic cancellation of PRRO registration. Therefore, after closing a property, check the cash register’s status. If its registration has been cancelled, it must be registered again for future use; an already cancelled PRRO cannot be re-registered.

How to report temporary non-use, closure, and repurposing

If the owner retains the property but temporarily does not use it, check whether you should report a status change: indicator “3” in field 2 and status “3 — temporarily not in operation” in field 14. The change must match the actual situation. For property with PRRO, consider the consequences for the cash register’s registration.

If the taxpayer sells the property, or a tenant returns it to the owner and stops using it, submit closure information with indicator “6.” An intention to sell the property or placing an advertisement for it does not, by itself, mean that the property has been disposed of.

A change of purpose or repurposing is subject to a special two-row rule set out in Clause 8.5 of Procedure No. 1588 and the form instructions:

• in the first row, report the property whose purpose is changing, with indicator “6 — closure,” status “7 — change of purpose/repurposing,” and its previous identifier;
• in the second row, report the property created or opened on its basis, with indicator “1 — initial information” and a new identifier.

Illustrative example. An entrepreneur stops using premises as a store entirely and repurposes them as a warehouse. They report the store’s closure and the warehouse’s opening in two rows, select the new property type, and change the identifier. Merely changing the storefront sign without changing the property’s purpose is not grounds for automatically applying this procedure.

How to correct an error in the statement

What to do depends on whether the tax authority accepted the previous document. If the statement was rejected, read the reason in the receipt, correct the document, and file it again. Before resubmitting, check the property records so you can correctly determine whether the information is initial. If the tax authority returned the documents specifically for registration of the taxpayer, take Clause 63.9 of the Tax Code of Ukraine into account: failure to submit corrected documents within five calendar days following the day the returned documents were received, or submitting them again with errors, incurs liability under the law. Check this condition in particular if you requested registration at a non-primary place of tax accounting through field 16.

The form instructions provide for indicator “3” when changing property details. Practical recommendation: if you need to correct an error in a statement that has already been accepted, check the record in the Electronic Cabinet and confirm the correction procedure with the tax authority at your primary place of tax registration, including whether a cover letter is needed. Keep the previous statement, receipts, and a document showing the correct details.

If the error concerns the identifier itself, creates a duplicate, or makes it unclear which record needs correction, first check the registered details and contact the tax authority at your primary place of tax registration to agree on how to correct the specific record. Before correcting an identifier, agree with the tax authority on how to link the correct details to the erroneous record, and consider possible consequences for PRRO registration if the record is closed.

Form No. 20-OPP is a statement about property. It does not calculate tax or an amount due. To change details, you do not need to invent a separate “amended Form 20-OPP tax return” or enter a penalty in the statement yourself.

What penalties apply to violations?

Clause 117.1 of the Tax Code of Ukraine provides for liability, including for failing to submit accounting documents by the deadline, failing to submit corrected documents, and submitting documents with errors or incomplete information.

The higher penalty applies if the violation is not remedied or if the same actions are committed within a year by a person who has already been penalized for that violation. Therefore, the statement “any second error within a year automatically doubles the penalty” does not capture all the conditions established by law.

Do not treat martial law as automatic confirmation that liability does not apply. If the deadline has already passed, the practical step is to submit the required information and keep the documents and receipts. Any possible exemption from liability must be assessed separately under the applicable legal grounds and the particular taxpayer’s documents.

What to check before completing the statement

• The statement includes all new property and all required changes, and property subject to separate state registration has not been combined contrary to the restrictions.
• The property type matches its purpose, and the identifier is correctly linked to an existing or new record.
• The address is split across fields 6–13, and the KATOTTG code is selected at the required level.
• The information submission indicator, actual status, and type of right are entered separately and match the documents.
• The receipts confirm acceptance, and the property details appear correctly in the Electronic Cabinet.
• The business unit’s name, address, and status match its PRRO registration, if PRRO is used.

Official sources and form

• Tax Code of Ukraine No. 2755-VI: Clause 63.3 — reporting property and primary and non-primary places of tax accounting; Clause 63.14 — date documents are received; Clause 117.1 — liability for violations of accounting requirements.
• Order No. 1588 of the Ministry of Finance of Ukraine, “On Approval of the Procedure for Taxpayer and Fee Payer Accounting”: Section VIII, Clauses 8.1–8.8 — property, deadlines, consolidation, changes, entry of information, and review of details.
• Appendix 10 to Procedure No. 1588: Form No. 20-OPP and its completion instructions — the 17-field form, indicator, status, and right codes, identifier rules, and address completion.
• Order No. 317 of the Ministry of Finance of Ukraine: Procedure for PRRO Registration, Register Maintenance, and Use: Section II, Clauses 6, 8–10; Section III, Clause 3; Section IV, Clauses 2, 4 — how business unit records relate to PRRO registration, re-registration, and use.