Overview of the Change
On 1 September 2026, Ukraine’s State Tax Service (STS) implemented revised mandatory reporting requirements for controlled transactions. A new unified main report, associated annexes, and updated signaling codes for related party status were introduced via Ministry of Finance Order № 312, registered with the Ministry of Justice under № 931/46325.(tax.gov.ua) These changes affect all entities required to submit information about cross-border or intercompany controlled transactions.(tax.gov.ua)
Key Sections and What’s New
| Component | Changes from 1 September 2026 |
|---|---|
| Name and structure of forms | Use identifiers: J0104708 for the main report; J0147108 for the annex; J0147208 for related party data.(tax.gov.ua) |
| Annex: “Information on related persons” | Two new codes—525 and 526—have been added to capture “economic relatedness” under Sub-paragraph 14.1.159 of Article 14 of the Tax Code.(tax.gov.ua) |
| Retrospective reports | Past reports (e.g., for 2025) submitted under old forms remain valid, are not needing resubmission simply due to format changes.(tax.gov.ua) |
What This Means in Practice
For Companies Involved in Controlled Transactions:
- Update your internal reporting templates to use the new form identifiers when preparing reports for tax periods from 1 September onward.
- Collect additional information to correctly apply the new relatedness codes (525, 526) where applicable.
- Ensure your tax software or document preparation processes are updated, and test submission via the STS portal to catch any technical issues early.
For Advisors and Tax Teams:
- Audit data scope: confirm that all past related-party relationships are disclosed under the expanded codes, including economic ties that may not involve formal ownership.
- Review historical documentation to make sure no critical data is missing, since new reporting may retrospectively lead to scrutiny of earlier periods.
- Communicate changes clearly to all units handling controlled transactions: accounting, legal, compliance.
Risks & Enforcement
While new forms are designed to streamline reporting, non-compliance risks remain: incomplete disclosure of related persons, miscategorization of relatedness, delayed submission. These could trigger audits or penalties under Ukraine’s Tax Code. STS has stated changes were made via a valid legal order, so legal basis is firm.(tax.gov.ua)
Action Plan Checklist
- ✅ Download updated report templates (J0104708, etc.) from STS portal.
- ✅ Map existing data fields to new codes 525, 526 for economic relatedness.
- ✅ Train staff or external preparers on new form structure.
- ✅ Adjust internal deadlines to allow for revisions ahead of the first submission period under new form (i.e., transactions after 1 September 2026).
- ✅ Review systems for electronic signatures or filings, ensuring interoperability with updated digital trust infrastructure (see note on "Kupina" standard below).
Related Policy: Transition to “Kupina” Standard for Qualified Electronic Signatures
Starting 1 September 2026, Ukraine switches to the modern “Kupina” national cryptographic standard for qualified electronic signatures.(tax.gov.ua) All previously issued certificates remain valid through their expiry, and both old and new standards will be interoperable during the transition.(tax.gov.ua)
This matters for e-filing tax forms like the controlled transactions report—electronic signatures must be compatible with the receiving systems and certificates. Update signer tools to include new “Kupina” certificates as needed.
Summary: Companies in Ukraine affected by controlled transactions must switch to updated reporting forms and codes starting 1 September 2026. While historical reports remain valid, procedures, systems and data gathering need prompt adjustment. Staying ahead will avoid filing errors, delays, or regulatory risk.