Compliance

Ukraine’s Emerging Tax Mediation & Audit Reforms: What Corporates Must Know

Ukraine is reducing audit frequency, focusing on high-risk cases, and drafting new mediation legislation—potentially transforming how businesses interact with tax authorities.

By NomadicTax Research Team • 6 min read • August 12, 2026

## What Reform Moves Are Underway in Ukraine From the State Tax Service announcements on **8 July 2026**, we know that Ukraine is: - Adopting a **risk-based approach** to tax audits, decreasing their number by about **17% in the first half of 2026** compared to the same period last year; audits will focus more narrowly on high-risk areas. ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/1028559.html?utm_source=openai)) - Preparing a **draft law on tax mediation**, in consultation with business associations and the Business Ombudsman Council, aimed at **speeding up tax dispute resolution** and improving fairness. ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/1028559.html?utm_source=openai)) - Releasing interactive public dashboards that track tax revenue collection and RRO/PRRO (cash register / fiscal device) transactions to **improve transparency** and help entities monitor how their sector, region, and payment methods contribute to tax enforcement. ([tax.gov.ua](https://www.tax.gov.ua/en/mass-media/news/1033890.html?utm_source=openai)) ## What Corporates Should Do Today ### 1. Audit Readiness & Risk Management - Map your business to identify **high-risk exposure areas** (e.g. value-added services, cross-border transactions, large cash flow). These may attract audit scrutiny under the risk-based model. - Reinforce proper documentation, especially for transactions with non-residents, related parties, and those involving excisable goods. Have clear internal practices for recordkeeping, especially digital receipt and RRO/PRRO transaction logs. ### 2. Engage on Mediation Frameworks - Stay tuned to how the draft law defines **scope of mediation**, who may initiate it, what disputes are mediated, and what procedural deadlines will apply. - Consider including a mediation clause in contracts where possible. - If disputes are ongoing, track whether they may qualify for mediation once law is enacted. ### 3. Use Public Data & Dashboards - Monitor the State Tax Service’s dashboards for your region/industry. These can offer early warning signals (if you deviate from norms) and help benchmark compliance against peers. ([tax.gov.ua](https://www.tax.gov.ua/en/mass-media/news/1033890.html?utm_source=openai)) - Use analytics to align cash/non-cash ratio, settlement methods, and product mix to what regulators are tracking. ## Case Example: A Mid-Sized Retailer in Kyiv Suppose you run a chain of stores doing both cash and non-cash transactions, use PRRO, deal in excisable goods like alcohol, and have suppliers abroad. Previously, you were audited every second year broadly. Under the new risk-based regime, your audit frequency might drop—but if your excisable goods sales are above average, or your non-cash/cash ratio deviates significantly, you may get flagged. By using your company data to match averages you find on dashboards, you can keep your profile safer. Also, mediation may help settle any disputes over VAT or customs valuation more quickly, with less cost in legal expenses. ## Timelines and Watch-Points - Draft law on tax mediation is **not yet effective**; it is in development. Once passed, watch its effective date. - Dashboards are **already live**; monthly updates expected. ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/print-1008065.html?utm_source=openai)) - Risk-based auditing is being implemented **now**, with audits reducing in number but increasing in focus. ([tax.gov.ua](https://tax.gov.ua/en/mass-media/news/1028559.html?utm_source=openai)) ## Summary Ukraine is moving toward more intelligent, data-driven tax compliance: fewer audits overall but sharper focus on risk; new mediation mechanisms promising more efficient dispute resolution; increasing transparency through dashboards. Corporates can minimize risk and cost by aligning their internal control, documentation, and business reporting with what the State Tax Service is increasingly monitoring.