Understanding the Policy: General vs. Personal Discounts
Published 2 September 2026, new guidance clarifies how discounts are treated under Ukrainian tax law. Among key distinctions: if a discount is offered universally—e.g. store-wide sale or discount card—it’s not taxable for buyers; if it’s given personally to a specific individual, the discount difference may be a taxable benefit. (tax.gov.ua)
Taxable Treatment of Personal Discounts
- Tax Agent Responsibility: Legal entities providing personal discounts must accrue, withhold, and remit applicable taxes on the discount amount. (tax.gov.ua)
- Tax Rates:
- Personal Income Tax: 18% applies to the personal discount benefit. (tax.gov.ua)
- Military Levy: An additional 5% for the same benefit. (tax.gov.ua)
- The taxable base is only the discount amount, not the full purchase price.
How This Operates in Practice
| Scenario | Universal Discount | Personal Discount |
|---|---|---|
| All shoppers get 10% off | Not taxable income | — |
| Loyalty card holders get special offer | If terms equal and public ⇒ not taxable | — |
| Specific individual gets a 20% discount others don’t | — | Discount amount (difference) is taxed at 18% + 5% |
What Stores and Buyers Need to Do
- Stores (Legal Entities):
- Track whether discounts are general or individually tailored.
- Maintain records of which customers received personal discounts and amounts.
- Withhold appropriate taxes and remit to the budget. (tax.gov.ua)
- Buyers (Individuals):
- No need to declare or pay tax themselves—tax agent handles it. (tax.gov.ua)
Example Case Study
Svitlana, a teacher, receives a special 30% discount on electronics from a supplier—no public advertisement. Original price is 10,000 UAH, discounted price 7,000 UAH, discount = 3,000 UAH. That 3,000 UAH is personal benefit; store must withhold (3,000 × 18%) = 540 UAH as personal income tax, (3,000 × 5%) = 150 UAH as military levy.
Why this matters
- Prevents misunderstandings and conflicts during audits.
- Ensures businesses properly apply deductions and record-keeping, avoiding potential penalties.
- Helps individuals avoid surprises—though taxable burden falls on the business.
Key Compliance Points
- Clearly define discount types—general vs. personal—in internal policies.
- Train staff handling customer pricing to identify when a discount is personalized.
- Update accounting systems to allocate tax withholding on personal discounts.
Bottom line: General discounts are tax-free, but personalized discounts are a taxable benefit. Legal entities must comply with withholding and remittance rules; individuals don’t need to act on them.