Return of Goods for Sole Traders: Process Without Risks
13.03.2026 12:09
Return of Goods and Funds for Individual Entrepreneurs and Legal Entities on a Single Tax: How to Process without Tax and Consumer Risks
For a seller on a single tax, returning goods is not only a matter of customer service but also a matter of law. To ensure the return is legal and does not result in additional tax charges, two groups of requirements must be met simultaneously: confirming the buyer's right to exchange or terminate the contract, and properly documenting the transaction itself, including through a cash register (RRO/PRRO) if applicable. For goods of proper quality, the 14-day rule applies only to non-food items that have not been used and are not included in the government's list of non-exchangeable/non-returnable goods. For defective goods, the buyer's rights are broader but depend on the warranty, the nature of the defect, and, in some cases, expert confirmation. (Legislation of Ukraine)
For a single tax payer, the key rule is: funds actually returned to the buyer for a product, work, or service are not included in income. But this cannot be just "in words". You need documents, the fact of the refund, proper reflection in accounting and tax returns, and, when working with a cash register, the correct settlement document and, in certain cases, an act of funds issuance. Otherwise, the return may not work for tax accounting or a State Tax Service audit. (Legislation of Ukraine)
Which Law Applies Now
As of the date of this response, the Law of Ukraine "On Consumer Rights Protection" No. 1023-XII is in effect in this area. The new Law No. 3153-IX has not yet come into force, so for returns in retail trade, the provisions of Law No. 1023-XII currently apply, and for goods of proper quality, the current government list of non-exchangeable (non-returnable) goods applies. (Legislation of Ukraine)
When the Buyer Has the Right to a Return or Exchange
1. Goods of Proper Quality
The buyer has the right to exchange a non-food product of proper quality within 14 days, not counting the day of purchase, if the product does not fit in shape, dimensions, style, color, size, or for other reasons cannot be used for its intended purpose. For this, the product must not be used, and its marketable condition, consumer properties, seals, labels, and settlement document — paper, electronic, or QR code that allows identifying the receipt — must be preserved. (Legislation of Ukraine)
If a similar product is not on sale, the buyer may: take another product with a recalculation of cost, wait for a similar product to arrive, or terminate the contract and get the money back. Upon termination of the contract, money is returned on the day of termination, or if impossible, at another agreed time, but no later than within 7 days. Returns are based on the cost of the product at the time of purchase. (Legislation of Ukraine)
This rule does not apply to goods from the government's list of those that cannot be exchanged or returned on the basis of "did not fit". The current list is approved by CMU Resolution No. 172. (Legislation of Ukraine)
2. Defective Goods
If defects are discovered during the warranty period, the buyer may demand: a proportional reduction in price, free elimination of defects within a reasonable time, or reimbursement of expenses for their elimination. If a significant defect that arose due to the fault of the manufacturer, seller, or executor is discovered, or the product is counterfeit, the buyer can choose to terminate the contract and get a refund or replace the product. If necessary, a significant defect is confirmed by an expert opinion. (Legislation of Ukraine)
The seller or manufacturer is obliged to accept defective goods. For bulky goods or goods weighing more than 5 kg, delivery to the seller, manufacturer, or service center and return to the buyer are at the expense of the seller, manufacturer, or authorized enterprise. (Legislation of Ukraine)
3. Distance Selling and Online Stores
For distance contracts, before concluding the contract, the seller must provide the consumer with information about themselves, location, and the procedure for accepting claims, main characteristics of the product, price including delivery, payment terms, warranty, other delivery conditions, the period for accepting the offer, and the procedure for terminating the contract. The consumer has the right to terminate such a contract within 14 days from the moment of confirming the information or from the moment of receiving the goods or the first delivery of goods. (Legislation of Ukraine)
If the seller cannot fulfill the order due to a lack of goods, they must notify the consumer no later than 30 days from receiving consent to conclude the contract. For distance trade, this means that return conditions, return delivery, and refund methods should ideally be specified in advance in the public offer, store rules, and internal regulations, but these conditions cannot narrow the consumer rights established by law. (Legislation of Ukraine)
What Documents the Seller Needs
To ensure the return works for both the consumer and tax block, the seller should have a full set of documents:
During the sale, the seller is obliged to issue a settlement document of the established form to the buyer or create it in electronic form no later than the moment of transfer of the goods or services. This exact document is most often the main basis for a subsequent return. (Legislation of Ukraine)
How to Process a Return via RRO/PRRO
When a seller conducts settlement operations through a cash register (RRO/PRRO), refunds must also be processed through the RRO/PRRO. The current Regulation, approved by the Ministry of Finance Order No. 13, requires a fiscal cash receipt for funds issuance according to form No. FKCH-2; it must contain mandatory details, and the payment form is shown as a separate detail. (Legislation of Ukraine)
If the amount of funds issued for returning goods or recompensing a previously paid service exceeds UAH 100, the financially responsible person of the business unit or the person directly conducting settlements must draw up an act on the issuance of funds. This act specifies the details of the document identifying the buyer, information about the product or service, the amount issued, and the number, date, and time of the original settlement document. The same act is drawn up when canceling an amount mistakenly processed through the RRO or a mistakenly selected payment method. (Legislation of Ukraine)
Acts on the issuance of funds and acts on the cancellation of mistaken settlements are kept for three years and must be provided to the regulatory authority during an inspection. (Legislation of Ukraine)
How a Return Affects the Single Tax
For a single tax payer, paragraph 292.11 of the Tax Code is critical: income does not include amounts of funds returned to the buyer for goods, works, or services, as well as funds returned by a single tax payer for other reasons, specifically due to a return of goods, termination of a contract, or a letter-request for a refund. This means that money actually returned to the buyer should not remain in the single tax base. (Legislation of Ukraine)
But the reduction in income must be documented. If a sale occurred and the funds are not actually returned to the buyer, there are no grounds for excluding this amount from income. That is why the internal package of documents for a return must be complete and consistent: the buyer's application, document of receiving goods back, document on the actual refund, and, if RRO/PRRO is available, an expense receipt and an act. (Legislation of Ukraine)
According to the official position of the State Tax Service, if the return occurred in the same tax period, it is reflected in the current declaration. If the return happened in a different tax period, the adjustment is usually made via a clarifying declaration for the period in which the income was reported. (Legislation of Ukraine)
How Long to Keep Documents
The Tax Code requires keeping documents related to the calculation and payment of taxes and fees for at least 1095 days. For acts on funds issuance under RRO rules, a separate requirement applies — three years. In practice, the return document package should be kept for at least the general tax period, and if it is part of a tax audit or dispute, until the full completion of such a dispute. (Legislation of Ukraine)
Common Seller Mistakes
The most common risks for a single tax seller are:
For violating the requirements of paragraphs 1 and 2 of Article 3 of the RRO Law, financial sanctions under Article 17 of this Law apply: 100% of the cost of goods, works, or services for the first violation and 150% for each subsequent one. For returns, this is risky when the seller does not properly conduct the operation via RRO/PRRO or fails to issue a proper settlement document. (Legislation of Ukraine)
Practical Example
A single tax store sold a product in March, and the buyer returned it in April due to a significant defect. The seller accepted the product back, processed the refund via PRRO, generated an expense receipt, and since the amount exceeded UAH 100, drafted an act of funds issuance. Since the return took place in a different tax period, income adjustment should not be left only in internal accounting: according to the STS position, a clarifying declaration should be filed for the period when the income was declared. (Legislation of Ukraine)
Workflow for Entrepreneurs
How to Process a Goods Return and Refund for a Client in Torgsoft
The program has built-in algorithms that automate this process, minimize the human factor (cashier errors), and protect the entrepreneur from tax risks. Here is exactly how this process is organized:
Torgsoft features automatic control of the return periods for goods. The business owner can set the maximum period in the program settings (by default, it is 14 days). If a client attempts to return a product after this period expires, the program issues a warning and prevents the cashier from completing the transaction without proper access rights.
Legislation defines a list of goods of proper quality not subject to return (e.g., underwear, hosiery). In Torgsoft, you can set the flag "Prohibit return of goods" for specific product types or manually apply this prohibition during a sale. If a buyer tries to return such an item, the program will block the action and display the reason for the prohibition on the screen.
For the refunded amount to legally not be included in your income, the return must go through a fiscal registrar or software cash register (PRRO).
This is critically important for the tax office. If a client paid by card, the money must return to the card; if in cash, it is issued from the till.
To avoid consumer fraud or internal staff machinations, a return in Torgsoft is always linked to a specific transaction:
If the seller simply made a mistake while ringing up a receipt (the client hasn't left yet, but the receipt is printed), a full return process isn't required in Torgsoft. You can use the "Receipt Reversal" function. Only the last registered receipt can be reversed — it gets canceled, sent to the tax server as voided, and is not counted in the Z-report totals.
Thus, the Torgsoft program closes the entire return cycle: from warehouse accounting (goods returning to stock) to financial control and legal fiscalization (generating a return receipt via RRO/PRRO).
Official Sources
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