The tax authorities are initiating a “pursuit” of Ukrainians' accounts abroad: what is in store for proprietors of assets overseas
On July 1, the State Tax Service (STS) finalized the acquisition of data from monetary institutions regarding their clients' accounts. This information is essential for the second cross-border transmission of tax details (CRC), scheduled for September, as per Mind publication.
As a quick reminder, during autumn of 2024, the State Tax Service performed the initial exchange of this type, leading to the gaining of details on no fewer than 500,000 external accounts belonging to Ukrainian nationals across 50 global regions. In the context of the second exchange, the State Tax Service aims to procure details concerning the accounts of Ukrainian citizens in excess of 110 regions.
The State Tax Service is accumulating details about the capital that Ukrainians prefer to keep outside the nation. Subsequently, the State Tax Service will employ data on external accounts to pinpoint unreported earnings and penalize individuals violating tax regulations.
The pursuit of taxpayers avoiding levies could commence as early as 2026: amplified scrutiny of individual earnings is outlined within the National Revenue Strategy and is anticipated in the fiscal declaration for 2026–2028.
Furthermore, the mechanism of global automated interchange of details for tax reasons will evolve into a pivotal instrument for observing citizens' international savings and earnings.
Journalists investigated what Ukrainian taxpayers possessing foreign bank accounts ought to anticipate.
What is the objective of global data interchange?
Ukraine integrated into the Common Reporting Standard (CRS) tax information exchange network during 2023, succeeding the enactment of Legislation No. 2970-IX. Its stipulations mandate that financial institutions convey customer account details to the State Tax Service through specified reports. Financial institutions formulate these reports on an annual basis, submitting them to the tax bodies before July 1.
The CRS data interchange mechanism encompasses tax authorities accumulating details regarding the accounts of individuals who are not residents and disseminating it among the tax bodies of other nations that have embraced the CRS standard, who in reciprocation, obtain data concerning their personal tax inhabitants.
For instance, the State Tax Service, upon obtaining information concerning the accounts of inhabitants of Switzerland, Germany, and France from Ukrainian banks or investment organizations, transmits this information to the tax bodies of these countries, and they, correspondingly, transmit to the State Tax Service information regarding the accounts of Ukrainians maintained within Swiss, German, and French banks.
As of July 2025, a total of 119 regions had adhered to the CRS (the complete listing is accessible here). Consequently, should Ukrainian citizens maintain accounts in any of the specified countries, the State Tax Service will possess the capability to ascertain it.
These predominantly encompass financial (banking) accounts, securities accounts, mutual fund holdings, pension fund accumulations, along with life assurance accounts.
How did the initial CRS interchange conclude?
The interchange of tax data transpires yearly. The initial interchange incorporated details concerning all novel accounts inaugurated between July 1, 2023, and December 31, 2023, furnished to the tax authority by financial intermediaries—banks, insurance and investment firms, payment infrastructures, among others.
As conveyed by the Ukrainian tax department, it transmitted taxpayer details to 51 regions and, conversely, obtained details from 50 regions concerning Ukrainians' accounts maintained across upwards of 1,650 international monetary institutions.
The STS clarified that on account of variances in the lawful framework governing issues pertaining to the CRS, data interchange had been executed with fewer than half of the nations that had integrated into the mechanism.
Nevertheless, during September 2025, upon the occurrence of the second interchange, the State Tax Service anticipates obtaining details concerning external financial accounts of Ukrainian tax inhabitants from all nations that are collaborators within the CRS standard.
Which specific data does the tax agency obtain?
Tax authorities of other regions furnish the State Tax Service with the ensuing details:
- the account holder's identity, location, and tax residency;
- individual tax identification number (ITN) of a person, date and locale of birth;
- specifics of the monetary institution wherein the account/accounts are opened;
- account equilibrium details, encompassing accrued interest, dividends, along with other earnings.
Significantly, the inaugural tax data interchange, which transpired during 2024, solely encompassed accounts with balances surpassing $1 million. During 2025, all accounts, irrespective of their balances, are projected to be incorporated within the interchange.
Yet, in all likelihood, the State Tax Service has already acquired details concerning not solely the millionaires but a multitude of other account proprietors during the preliminary interchange. The manner in which this occurred will be further deliberated.
How many accounts do Ukrainians possess abroad?
Details concerning the quantity of accounts Ukrainians genuinely possess abroad and the magnitude of funds within them remains inaccessible to the public.
Even the parliament's Finance and Tax Committee, in response to an inquiry from Mind, refuted possessing such data. Nonetheless, the committee's chief, MP Danylo Hetmantsev, during an interview with Novosti.live, articulated that the State Tax Service, via a global interchange, had already procured details on 500,000 accounts external to Ukraine with balances exceeding €200,000.
Thus, it can be deduced that the tax bodies presently possess details concerning the foreign accounts of Ukrainian nationals, which in aggregate (according to exceedingly approximate valuations) encompass 100 billion euros or greater.
The sole query pertains to why we are referencing accounts with a balance of 200 thousand euros, if the initial data interchange was anticipated to solely encompass those accounts with upwards of $1 million.
As experts elucidate, the demarcation between low-value accounts (under $1 million) and high-value accounts (over $1 million) is solely intended for subsequent verification of such accounts alongside their proprietors. Nonetheless, the account equilibrium does not impinge upon its inclusion in reporting throughout information interchange.
Therefore, it’s plausible that the preliminary data interchange already incorporated accounts with diminished values (for instance, commencing from 200,000 euros). All the same, should the State Tax Service resolve to conduct an audit (or has previously conducted one), it will presently concentrate on accounts with balances exceeding $1 million.
As for the secondary interchange, upon the State Tax Service being capable of obtaining data from all participants within the CRS standard (which, as a reminder, constitutes 119 regions), we would dare to presume that the quantity of accounts that the Ukrainian tax authority will be knowledgeable about will considerably surpass 1 million.
How does the interchange of tax details transpire?
| Parameters | CRS exchange (September 2024) | CRS exchange (September 2025) |
| Which accounts are eligible for exchange? | Balance over $1 million | All foreign accounts, regardless of balance |
| Number of jurisdictions participating in the exchange | 50 countries | 119 countries* |
| How many accounts have been/will be identified? | 500,000 | More than 1 million* |
Data from the State Tax Service, the Ministry of Finance, and other open sources. *Mind assessment
How will the tax authorities use data on foreign accounts?
The State Tax Service and the Ministry of Finance make no secret of the fact that information about Ukrainians' foreign accounts is needed to augment tax enforcement.
The Ministry of Finance, alluding to the National Revenue Strategy, declared that access to data on foreign financial assets of Ukrainian inhabitants will permit:
- reinforce oversight over the timeliness and exhaustiveness of declarations of taxable earnings;
- pinpoint unreported earnings to contest tax avoidance;
- enhance the efficacy of employing the regulations on taxation of controlled international corporations;
- procure an additional origin of tax details when implementing indirect methodologies of oversight over taxation of persons.
The Ministry additionally clarifies that via interchanging such data, Ukraine will be equipped to amplify tax revenues to the state treasury.
The State Tax Service, in return, proclaimed that, subsequent to the CRS interchange, it will not solely scrutinize details concerning external financial accounts (balances and circulation of funds), but additionally juxtapose the procured data with the tax filings submitted by the proprietors of these accounts.
Consequently, should the State Tax Service uncover discrepancies amid the details it obtained from foreign tax bodies and the data within their tax returns (and it's entirely conceivable that numerous foreign account proprietors never proclaimed their earnings whatsoever), it will evaluate supplementary tax liabilities. As a reminder, external earnings are subject to individual income tax at a rate of 18% and military taxation at a rate of 1.5%.
In the coming times, once the legislative structure is primed, the tax bodies will likewise be capable of employing data concerning accounts maintained external to Ukraine to compute the tax foundation utilizing indirect methodologies (scrutiny of an individual's actual earnings premised upon their expenditures and savings).
Nevertheless, until martial law concludes, account proprietors with balances less than $250,000 can be at ease. As per the Tax Code, details concerning external accounts of persons with balances beneath this sum cannot be employed to compute tax liabilities. However, it's worthwhile to recall that the State Tax Service will nonetheless possess details concerning these accounts. And subsequent to martial law being revoked, they will be subject to surveillance akin to all other accounts.
Author: Sergey Kucherenko
