The coordinator of the expert groups of the Economic Expert Platform, an associated expert of CASE Ukraine, Oleg Getman, analyzed several initiatives of the program in more detail for Forbes Ukraine
Positive points
1. Eliminate customs loopholes for the import of consumer goods
This IMF proposal refers to a benefit for parcels from China up to €150, which currently arrive in Ukraine without VAT and import duty. While VAT is charged on similar Ukrainian goods. According to research, Ukrainians most often receive from Chinese marketplaces: clothing, footwear, electronics, cosmetics, household goods, and toys. Almost all of these goods are mass-produced in Ukraine.
Such a benefit creates unequal competition, discriminates against Ukrainian producers, leads to budget losses, and promotes “gray” schemes. Therefore, this issue needs to be resolved. The cost of international postal and express shipments imported into Ukraine in the first six months of 2025, without taxation, amounted to UAH 44.6 billion. The total loss of revenues to the state budget from the application of the benefit for parcels will amount to UAH 17.9 billion in 2025. With the current dynamics of volume growth, in 2026, the shortfall in revenues to the state budget will amount to UAH 27 billion.
The IMF proposal to switch to the European one-stop shop model, when Chinese marketplaces start paying VAT on goods sent to Ukraine, and consumers will not experience any changes in administration, is a positive step for the Ukrainian economy.
2. Taxation of digital platforms
After joining the Multilateral DPI Agreement, the State Tax Service of Ukraine (STS) will receive information from foreign partners every year on the income of Ukrainians earned through Uber, Etsy, Upwork, or other international platforms. And vice versa, it will transmit information on the income of foreigners received in Ukraine. Deputies have already registered the relevant draft law No. 14025, which provides for the implementation of DAC7 and creates a super-simplified tax regime for self-employed people working through digital platforms. An individual will not need to register as an individual entrepreneur or file a declaration.
The platform will automatically withhold 5% of personal income tax and (until the end of martial law) 5% of military levy. After the end of martial law, such taxation will be the most liberal among other taxation systems. The law will not apply to ordinary bulletin board platforms such as OLX or Aviso, if users place ads there and receive money for goods in cash or to their own account.
3. Eliminate gaps in labor legislation
The problem with the current labor legislation of Ukraine is the lack of clear criteria for labor relations, by which it would be possible to determine whether a real freelancer or an employee (who has registered as an individual entrepreneur and the company minimizes taxes) is working. This is the so-called “individual entrepreneur instead of hiring” scheme, the losses of the state budget from which, according to experts, are 16-19 billion UAH per year. To solve this problem, it is necessary to implement clear labor criteria in the legislation. For this purpose, draft law No. 13507 has been developed and registered, which is currently not moving in parliament.
Negative point: Cancel privileges for VAT registration
The proposal in the Memorandum, according to preliminary information, is that for individual entrepreneurs of groups 2 and 3, a threshold for transition to VAT should be introduced, approximately when reaching a turnover of UAH 1 million per year. Such a norm will not help minimize “gray” schemes and will not increase VAT revenues, but, on the contrary, will provoke the fragmentation of small businesses and concealment of turnover, as was already the case when the threshold for transition to RRO was set at UAH 1 million in turnover.
To minimize this scheme, which is far from the largest in Ukraine, it is necessary to introduce several measures, but in no way reduce the VAT threshold for the simplified system: introduce a general anti-tax evasion rule (GAAR) into the legislation, and a rule to combat fragmentation.
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