TAX HOLIDAYS. BUSINESS AND QUARANTINE. UKRAINE | UBC

Tax holidays and anti-crisis measures for business

This page was prepared during the COVID-19 pandemic and reviewed temporary tax reliefs, deadline extensions, a moratorium on certain audits and exemptions from certain payments. It is historical material: the dates and reliefs described in it have expired and cannot be applied to 2026 operations.

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What the temporary reliefs meant

Anti-crisis laws could, for a certain period, restrict documentary and factual audits, extend the deadline for filing the annual return, or change the procedure for charging land fees or tax on non-residential property. At the same time, certain breaches, including those involving VAT, excise tax, fuel and tax liens, remained outside the moratorium.

The main conclusion is that a tax relief should never be applied only from a news headline. The effective date, eligible taxpayers, period of application, exceptions and reporting rules must be checked.

How to act during a systemic crisis

The pandemic showed that an enterprise needs not a one-off savings plan but a continuity mechanism. Management should identify critical functions, a minimum liquidity reserve, replacement key suppliers, remote access to accounting and a procedure for signing documents when the office is unavailable.

Online sales, electronic contracts, remote work and foreign markets can support revenue, but they create new tax, currency, consumer and banking issues. Entry into another market should not be reduced to opening a foreign company or bank account without analysing residence, CFC rules, permanent establishment and the place from which management is exercised.

Lessons for business in Ukraine in 2026

War-related risks were added to the pandemic risks: interruptions to electricity and communications, movement of personnel, restrictions on currency operations, logistics delays, mobilisation issues and damage to assets. The anti-crisis plan should therefore include backup communication channels, copies of documents, an alternative bank, insurance where available and a data-recovery procedure.

Tax decisions during martial law can also be temporary. Before filing a return or not performing an ordinary obligation, the current version of the Tax Code, State Tax Service guidance and transitional provisions should be checked.

Checklist

• prepare a tax and reporting calendar marking temporary rules;
• check each relief against the primary legal act;
• prepare a liquidity reserve and scenarios for a fall in revenue;
• set up remote access, qualified electronic signatures and backups;
• review contracts for force majeure, deadlines and notification methods;
• keep documents confirming the effect of extraordinary circumstances on performance of obligations.

previous reliefs may be useful for analysing past periods, tax disputes or restoring accounting records, but they are not a recommendation for current transactions.

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