Ukraine VAT (PDV) Return Preparation Skill

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Skill Metadata

Field	Value
Jurisdiction	Ukraine (Ukraina)
Jurisdiction Code	UA
Primary Legislation	Podatkovyi Kodeks Ukrainy (Tax Code of Ukraine, TCU), Law No. 2755-VI of 2 December 2010
Supporting Legislation	CMU Resolutions on VAT administration; Order of Ministry of Finance on PDV return form; Law on Electronic Administration of VAT
Tax Authority	Derzhavna Podatkova Sluzhba (DPS -- State Tax Service of Ukraine)
Filing Portal	https://cabinet.tax.gov.ua (Electronic Cabinet of Taxpayer)
Validated By	Deep research verification, April 2026
Validation Date	April 2026
Skill Version	1.0
Confidence Coverage	Tier 1: rate classification, return field assignment, reverse charge, tax invoice registration, SEA PDV mechanics. Tier 2: wartime temporary provisions, agricultural special regime (legacy), partial exemption. Tier 3: group structures, free economic zones, occupied territory transactions.

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Confidence Tier Definitions

Every rule in this skill is tagged with a confidence tier:

• [T1] Tier 1 -- Deterministic. Apply exactly as written. No reviewer judgement required.
• [T2] Tier 2 -- Reviewer Judgement Required. Flag the issue and present options. A qualified tax adviser must confirm before filing.
• [T3] Tier 3 -- Out of Scope / Escalate. Skill does not cover this. Do not guess. Escalate to qualified tax adviser and document the gap.

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Wartime Provisions Notice [T2]

IMPORTANT: Since 24 February 2022, martial law (voiennyi stan) has been in effect in Ukraine. Temporary legislative provisions affect PDV administration:

Provision	Impact	Status
Extended filing deadlines	Taxpayers in combat zones may have extended deadlines	Active during martial law
Tax invoice registration grace period	6 months after martial law ends to register invoices that could not be registered during hostilities	Active
Destroyed/lost goods	Input PDV on goods destroyed due to hostilities is not reversed, but cannot be refunded in cash -- offset only	Active
Free supply to Armed Forces	Supply of goods/services free of charge to the Armed Forces of Ukraine is not treated as a taxable supply	Active
Import exemptions	Certain military goods and humanitarian aid imports are PDV-exempt	Active
Simplified registration	Simplified voluntary registration available for certain entities	Active

Flag for reviewer: All filings during martial law should be reviewed for applicability of temporary provisions. Provisions may be extended, modified, or terminated by Verkhovna Rada (parliament).

Legislation: Tax Code of Ukraine, Transitional Provisions; Laws No. 2118-IX, 2120-IX, and subsequent amendments

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Step 0: Client Onboarding Questions

Before classifying ANY transaction, you MUST know these facts about the client. Ask if not already known:

1. Entity name and EDRPOU code (or RNOCPP for individuals) [T1] -- EDRPOU is 8-digit code for legal entities; RNOCPP is 10-digit individual tax number
2. PDV registration number (IPN -- Individualnyi Podatkovyi Nomer) [T1] -- 12-digit number assigned upon PDV registration
3. Registration type [T1] -- Mandatory PDV payer, voluntary PDV payer, or non-registered (below threshold)
4. Filing period [T1] -- Monthly (standard for all PDV payers)
5. Industry/sector [T2] -- Impacts specific rates (7%, 14%) and exemption rules
6. Does the business make exempt supplies? [T2] -- If yes, proportional allocation required (Article 199 TCU)
7. SEA PDV account balance [T1] -- Electronic administration system account balance (affects ability to register tax invoices)
8. Is the client in a territory affected by hostilities? [T2] -- Wartime provisions may apply
9. PDV credit carried forward from prior period [T1] -- Vidiemnne znachennia PDV
10. Does the client export goods or services? [T1] -- Zero-rated; refund eligibility

If any of items 1-4 are unknown, STOP. Do not classify any transactions until confirmed.

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Step 1: Transaction Classification Rules

1a. Determine Transaction Type [T1]

• Sale (output PDV -- podatkove zoboviazannia) or Purchase (input PDV -- podatkovyi kredyt)
• Salaries (zarobitna plata), social contributions (YeSV), tax payments, loan repayments, dividends = OUT OF SCOPE (never on PDV return)
• Legislation: Tax Code of Ukraine, Article 185 (taxable transactions)

1b. Determine Counterparty Location [T1]

• Domestic (Ukraine): Supplier/customer is in Ukraine (government-controlled territory)
• EU: EU member states (not relevant for intra-community rules as Ukraine is not an EU member, but relevant for place of supply)
• Foreign: All countries outside Ukraine
• Temporarily occupied territories (TOT): Crimea and parts of Donetsk, Luhansk, Zaporizhzhia, Kherson oblasts [T3] -- special rules; escalate
• Note: Ukraine is NOT an EU member state. No intra-community supply rules apply. Ukraine is an EU candidate country.
• Legislation: TCU Article 185-186 (place of supply)

1c. Determine PDV Rate [T1]

Rate	Category	Legal Basis
20%	Standard rate (zagalna stavka)	TCU Article 193.1
14%	Reduced rate (for certain agricultural products)	TCU Article 193.1
7%	Reduced rate (medicines, medical devices)	TCU Article 193.1
0%	Zero-rated (exports, international transport)	TCU Article 195

1d. Standard Rate (20%) Applies To [T1]

• All goods and services not specifically listed for reduced rates, zero rate, or exemption
• Professional services (legal, accounting, consulting, IT)
• Telecommunications and electronic services
• Construction services and materials
• Motor vehicles (new and used)
• Electronics, furniture, clothing
• Restaurant and catering services
• Real property transactions (excluding residential -- first supply)
• Legislation: TCU Article 193.1

1e. Reduced Rate -- 7% [T1]

Category	Examples	Legal Basis
Medicines	Registered medicinal products on approved list	TCU Art 193.1(1)
Medical devices	Registered medical devices and equipment	TCU Art 193.1(1)
Certain cultural services	Admission to theaters, museums, exhibitions	TCU Art 193.1
Periodicals (newspapers, magazines)	Print and digital periodicals	TCU Art 193.1

1f. Reduced Rate -- 14% [T1]

Category	Examples	Legal Basis
Certain agricultural products	Soybeans, rapeseed, sunflower seeds, corn, sugar beet, flax, hemp	TCU Art 193.1
Milk (raw)	Supplied by agricultural producers	TCU Art 193.1
Livestock (live weight)	Cattle, pigs, poultry -- supplied by agricultural producers	TCU Art 193.1

Note: The 14% rate was introduced in 2021 (replacing the abolished special agricultural regime) and applies to a specific list of agricultural commodities.

1g. Zero-Rated Supplies [T1]

• Export of goods (Article 195.1.1) -- goods must leave Ukraine customs territory, confirmed by customs declaration
• International transport of passengers and cargo (Article 195.1.3)
• Supplies to duty-free shops (Article 195.1.4)
• Supplies of gold to the National Bank of Ukraine (Article 195.1.5)
• Toll processing services on goods subsequently exported (Article 195.1.6)
• Note: Zero-rated suppliers can claim full input PDV refund
• Legislation: TCU Article 195

1h. Exempt Supplies (Without Input PDV Recovery) [T1]

Category	Legal Basis
Financial and banking services	Art 197.1.1
Insurance services	Art 197.1.2
Education services (licensed institutions)	Art 197.1.7
Healthcare services (licensed institutions)	Art 197.1.5
Postal services (Ukrposhta -- universal service)	Art 197.1.3
Residential rent	Art 197.1.14
Land transactions (except building land)	Art 197.1.21
Religious organizations (sales of religious items)	Art 197.1.8
Precious metals to NBU	Art 197.1.9
Social housing (first supply)	Art 197.1.14
Funeral services	Art 197.1.10

Note: Exempt suppliers CANNOT recover input PDV on related purchases (Article 198.4)

Legislation: TCU Article 197

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Step 2: PDV Return Structure

The PDV return (Podatkova deklaratsiia z PDV) is filed electronically via the taxpayer's electronic cabinet. Monthly filing is mandatory for all PDV payers.

Section I: Tax Obligations (Output PDV -- Podatkovi Zoboviazannia) [T1]

Line	Description	Notes
1	Supply of goods/services at 20% -- base	Net value
1.1	PDV at 20%	= Line 1 x 20%
2	Supply of goods/services at 7% -- base	Net value
2.1	PDV at 7%	= Line 2 x 7%
3	Supply of goods/services at 14% -- base	Net value
3.1	PDV at 14%	= Line 3 x 14%
4	Export of goods (0%)	Zero-rated base
5	Other zero-rated supplies	Other Art 195 supplies
6	Exempt supplies (Art 197)	Exempt base (informational)
7	Supplies not subject to PDV	Out-of-scope (informational)
8	Self-assessed PDV on imported services	Reverse charge output
8.1	PDV on imported services	= Line 8 x applicable rate
9	Total output PDV	= 1.1 + 2.1 + 3.1 + 8.1

Section II: Tax Credit (Input PDV -- Podatkovyi Kredyt) [T1]

Line	Description	Notes
10	Domestic purchases with PDV -- base	From registered tax invoices
10.1	Input PDV on domestic purchases	From tax invoices
11	Import of goods -- base	From customs declarations
11.1	Import PDV	From customs declarations
12	Input PDV on imported services (reverse charge offset)	= Line 8.1
13	Adjustment increase (from calculation of Art 192, 199)	Corrections increasing credit
14	Adjustment decrease (from calculation of Art 192, 199)	Corrections decreasing credit
15	Credit from prior periods (negative value carried forward)	Vidiemnne znachennia
16	Total input PDV	= 10.1 + 11.1 + 12 + 13 - 14 + 15

Section III: Calculation of PDV Payable or Credit [T1]

IF Line 9 > Line 16 THEN
    Line 18 (PDV payable / suma PDV do splaty) = Line 9 - Line 16
    Line 19 = 0
    Line 20 = 0
ELSE
    Line 18 = 0
    Line 19 (Negative value / vidiemnne znachennia) = Line 16 - Line 9
    Line 20.1 (Amount declared for budget refund) = portion of Line 19 requested as refund [T2]
    Line 20.2 (Carry-forward to next period) = Line 19 - Line 20.1
END

Legislation: TCU Articles 200-200a; Ministry of Finance Order on PDV return form

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Step 3: Electronic Administration System (SEA PDV)

3a. Overview [T1]

Ukraine operates a unique Electronic Administration System for VAT (Systema Elektronnogo Administruvannia PDV -- SEA PDV). Each PDV payer has a special account (rakhunok v SEA PDV) at the State Treasury.

Feature	Details
Purpose	Control registration of tax invoices; prevent fraudulent input PDV claims
Account	Each PDV payer has a virtual account in the Treasury
Registration limit	Tax invoices can only be registered if the SEA PDV account has sufficient balance
Balance formula	See 3b below

Legislation: TCU Article 200-1

3b. SEA PDV Account Balance Formula [T1]

Registration Limit (reiestratsiyni limit) =

  + PDV paid to the SEA account (bank transfers to Treasury)
  + Input PDV from registered tax invoices received
  + Import PDV paid at customs
  + PDV overpayment from prior periods
  + Adjustment notes received
  - Output PDV from registered tax invoices issued
  - PDV declared for budget refund
  - Adjustment notes issued

Key principle: You CANNOT register a tax invoice (podatkova nakladna) if your SEA PDV account balance is insufficient. If the registration limit is too low, the taxpayer must either:

1. Wait for incoming tax invoices from suppliers to increase the balance, or
2. Transfer funds (top-up) to the SEA PDV account at the Treasury

3c. Consequences of Non-Registration [T1]

Scenario	Consequence
Tax invoice not registered within 15 days	Buyer cannot claim input PDV
Tax invoice registered late (after 15 days)	Buyer can claim input PDV only after registration, but seller faces a fine
Tax invoice not registered at all	Buyer has NO input PDV right; seller faces fines
Wartime grace period	Tax invoices that could not be registered during hostilities may be registered within 6 months after martial law ends [T2]

Legislation: TCU Article 201.10

3d. Tax Invoice (Podatkova Nakladna) Requirements [T1]

Requirement	Details
Format	Electronic only (since 1 January 2017)
Registration	Must be registered in the Unified Register of Tax Invoices (YERPN) within 15 calendar days
Mandatory fields	Supplier and buyer IPN, date, sequential number, description, quantity, unit price, PDV amount, rate
Self-invoice (samoinvois)	Required for reverse charge on imported services (supplier section left blank or shows non-resident)
Correction (rozrakhunok koryguvannia)	Adjustment document for changing registered tax invoices
Blocking	Tax invoices may be automatically blocked by the SMKOR system (monitoring criteria) -- see 3e

3e. Tax Invoice Blocking (SMKOR) [T2]

• The automatic monitoring system (SMKOR -- Systema Monitoryngu Kryteriiv Otsinky Ryzykiv) may block registration of tax invoices deemed high-risk
• Blocking criteria include: new registrants, mismatched volumes, suspicious patterns
• If blocked, the taxpayer must submit explanations and supporting documents to unblock
• Unblocking decision by a regional commission within 5 business days
• If not unblocked, the taxpayer can appeal to court
• Flag for reviewer: Blocking events should be tracked; they can delay input PDV claims for buyers
• Legislation: TCU Article 201.16; CMU Resolution No. 1165

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Step 4: Reverse Charge Mechanics [T1]

4a. Import of Goods [T1]

• PDV on imported physical goods is assessed and collected by Customs (Derzhavna Mytna Sluzhba)
• Importer pays PDV at the border via customs declaration (mytna deklaratsiia)
• This import PDV is deductible as input PDV (Line 11.1)
• Import PDV paid at customs also increases the SEA PDV registration limit
• Do NOT self-assess imports of goods on the PDV return -- Customs handles assessment
• Legislation: TCU Article 190, 206

4b. Import of Services (Reverse Charge) [T1]

• When a Ukrainian PDV payer receives services from a non-resident with no permanent establishment in Ukraine:
  1. Self-assess PDV at the applicable rate (20%, 7%, or 14%) on the service value
  2. Report in Line 8 (base) and Line 8.1 (PDV)
  3. Register a self-invoice (podatkova nakladna) in YERPN
  4. Claim input PDV in Line 12 (= Line 8.1)
  5. Net effect: zero for fully taxable businesses
• Legislation: TCU Article 208

4c. Non-Resident Digital Services [T2]

• Since 1 January 2022, non-resident providers of electronic services (e-services) to Ukrainian individuals (B2C) must register for PDV and charge 20%
• Applies to: streaming services, app stores, online advertising, cloud services (B2C)
• B2B: standard reverse charge by the Ukrainian business applies (not the foreign provider)
• Flag for reviewer: Determine if the foreign provider is already registered and charging PDV (B2C) or if the Ukrainian business should self-assess (B2B)
• Legislation: TCU Article 208-1

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Step 5: Deductibility Rules

5a. General Deduction Right [T1]

• All input PDV on goods and services used for taxable business activities is deductible
• Input PDV must be confirmed by a registered tax invoice (podatkova nakladna) in YERPN or customs declaration
• If the tax invoice is not registered in YERPN, the buyer CANNOT claim input PDV
• Legislation: TCU Article 198

5b. Non-Deductible Input PDV [T1]

The following input PDV is BLOCKED and cannot be recovered:

Category	Legal Basis	Notes
Passenger vehicles (lehkovyi avtomobil)	Art 198.4 / Art 139.1.6	Exception: taxi, rental car, emergency services
Goods/services not used in business	Art 198.4	Personal consumption
Purchases without registered tax invoice	Art 198.6	No YERPN registration = no credit
Goods/services for exempt activities	Art 198.4	No input PDV on exempt supplies
Entertainment (if not business-related)	Art 198.4 / Art 139.1.1	Flag for reviewer [T2]
Goods destroyed/stolen (non-wartime)	Art 198.5	Must reverse previously claimed input PDV

5c. Vehicle Deductibility Rules [T1]

Vehicle Type	Input PDV Deductible	Notes
Private passenger car (lehkovyi avtomobil)	NO	Blocked
Taxi (licensed)	YES	Business use vehicle
Rental car (by rental company)	YES	Business stock
Delivery van (classified as vantazhnyi)	YES	Commercial vehicle
Truck (vantazhnyi avtomobil)	YES	Commercial vehicle
Bus	YES	Commercial vehicle
Ambulance / emergency	YES	Special purpose vehicle
Fuel for blocked vehicle	NO	Follows vehicle classification
Fuel for deductible vehicle	YES	Follows vehicle classification

5d. Proportional Allocation (Article 199) [T2]

• If a business makes both taxable and exempt supplies, input PDV on shared overhead must be proportionally allocated
• Formula: Deductible % = (Taxable + Zero-Rated Supplies) / Total Supplies x 100
• Calculated based on prior year's proportions; adjusted annually (re-calculation in December return)
• Threshold: if taxable supplies are >= 97% of total, the business may treat all input PDV as deductible (no allocation needed)
• Flag for reviewer: Proportional allocation must be confirmed by qualified tax adviser
• Legislation: TCU Article 199

5e. Destroyed and Lost Goods [T1]

• If goods for which input PDV was claimed are destroyed or lost, the input PDV must be reversed (charged as output PDV)
• Exception (wartime): Goods destroyed as a result of hostilities (Russian aggression) are NOT subject to input PDV reversal [T2]
• However, wartime-destroyed goods PDV cannot be refunded in cash -- can only offset future liabilities
• Flag for reviewer: Documentation of wartime destruction required (military administration confirmation)
• Legislation: TCU Article 198.5; Transitional Provisions

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Step 6: PDV Refund Mechanism

6a. Refund Eligibility [T1]

• When input PDV exceeds output PDV (negative value / vidiemnne znachennia), the excess can be:
  1. Carried forward to the next period (Line 20.2), OR
  2. Declared for budget refund (Line 20.1)
• Budget refund is available if the negative value is confirmed by the SEA PDV account balance

6b. Refund Process [T1]

Step	Timeline	Notes
Declaration filed	By filing deadline	Refund amount declared in Line 20.1
DPS verification	30 calendar days (standard) / 60 days (audit)	DPS checks YERPN registrations and SEA balance
Refund conclusion	Within 5 days after verification	DPS issues refund conclusion to Treasury
Payment	Within 5 business days after conclusion	Treasury transfers to taxpayer's bank account

6c. Automatic Refund [T1]

• Taxpayers meeting "risk criteria" (positive compliance history) are eligible for automatic refund without desk audit
• Criteria: registered for 24+ months, no tax debt, director not under criminal investigation, sufficient operational activity
• Legislation: TCU Article 200.19-200.20

6d. Refund Delays and Issues [T2]

• Refund delays are common in practice, especially during wartime
• If DPS misses the 30/60-day deadline, the taxpayer is entitled to interest
• If the refund is rejected, the taxpayer can appeal administratively (within 10 days) or judicially
• Flag for reviewer: Track refund applications and follow up on overdue refunds
• Legislation: TCU Article 200

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Step 7: Key Thresholds

Threshold	Value	Notes
Standard PDV rate	20%	TCU Art 193.1
Reduced PDV rate (medicines)	7%	TCU Art 193.1
Reduced PDV rate (agriculture)	14%	TCU Art 193.1
Mandatory registration	UAH 1,000,000 (last 12 months)	TCU Art 181.1
Tax invoice registration deadline	15 calendar days from date of supply	TCU Art 201.10
Proportional allocation threshold	97% taxable = no allocation needed	TCU Art 199
Automatic refund eligibility	24+ months registered	TCU Art 200.19
Document retention	1,095 days (3 years) from filing deadline	TCU Art 44.3
SEA PDV top-up	No minimum	Voluntary transfer to Treasury

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Step 8: Filing Deadlines

Return	Period	Filing Deadline	Payment Deadline
PDV return (standard)	Monthly	20th of the following month	10 calendar days after filing deadline (i.e., 30th)
PDV return (wartime extended)	Monthly	May be extended for taxpayers in combat zones [T2]	Correspondingly extended
Correction return (utochniuiucha)	N/A	Anytime (corrections to prior periods)	Additional PDV + 3% self-assessed penalty

Filing method: Electronic only via the Electronic Cabinet of Taxpayer (Elektronyi Kabinet Platnyaka Podatkiv).

Legislation: TCU Article 49, 203

Late Filing and Payment Penalties [T1]

Violation	Penalty
Late filing (first occurrence in year)	Warning (no fine)
Late filing (repeated)	UAH 340
Late filing (continued, 30+ days late)	UAH 1,020
Late payment	Penalty interest (penia): 120% of NBU discount rate per annum, calculated daily
Failure to register tax invoice (within 15 days)	10% of PDV amount on the invoice
Failure to register tax invoice (16-30 days late)	20% of PDV amount
Failure to register tax invoice (31-60 days late)	30% of PDV amount
Failure to register tax invoice (61+ days late)	40% of PDV amount
Non-registration (no invoice issued at all)	50% of PDV amount

Note: Wartime provisions may suspend certain penalties for taxpayers in territories with active hostilities [T2].

Legislation: TCU Articles 120-1, 126-1, 163

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Step 9: Place of Supply Rules

9a. Supply of Goods [T1]

Scenario	Place of Supply	Legal Basis
Goods located in Ukraine at time of supply	Ukraine	Art 186.1(a)
Goods dispatched from Ukraine	Ukraine	Art 186.1(a)
Goods imported into Ukraine	Ukraine (at customs)	Art 186.1(c)
Goods exported from Ukraine	Ukraine (zero-rated)	Art 195

9b. Supply of Services [T1]

Scenario	Place of Supply	Legal Basis
B2B (general rule)	Where the recipient is registered	Art 186.4
B2C (general rule)	Where the supplier is registered	Art 186.4
Real estate related	Where the property is located	Art 186.2.2(a)
Cultural, artistic, sporting events	Where event takes place	Art 186.2.1(a)
Transport of goods	Where transport occurs (proportionally)	Art 186.2.3
Restaurant/catering	Where services performed	Art 186.2.2(b)
Electronic services (B2C from non-resident)	Where buyer is located (Ukraine)	Art 208-1

Legislation: TCU Articles 185-186

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Step 10: Agricultural Sector Special Rules

10a. Former Special Regime (Historical Context) [T1]

• Until 31 December 2016, agricultural producers could use a special PDV regime where PDV collected was retained by the producer (not remitted to the budget)
• This regime was abolished from 1 January 2017
• The 14% reduced rate was introduced in 2021 as a partial substitute for certain agricultural commodities

10b. Current Agricultural Rules [T1]

Item	Rate	Notes
Soybeans	14%	On the specified list
Rapeseed (canola)	14%	On the specified list
Sunflower seeds	14%	On the specified list
Corn (maize)	14%	On the specified list
Sugar beet	14%	On the specified list
Flax, hemp (industrial)	14%	On the specified list
Raw milk (from farms)	14%	Agricultural producer supply
Live cattle, pigs, poultry	14%	Agricultural producer supply
Wheat, barley, rye	20%	NOT on the 14% list (standard rate)
Processed food products	20%	Manufacturing, not agriculture
Fresh vegetables (domestic market)	20%	Standard rate (unlike Israel)
Meat (processed/retail)	20%	Standard rate

Legislation: TCU Article 193.1; CMU list of 14% goods

10c. Agricultural Input PDV [T1]

• Agricultural producers claim input PDV on standard terms (same as all other businesses)
• No special retention or separate accounting (unlike the former special regime)
• Legislation: TCU Article 198 (general rules apply)

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Step 11: Edge Case Registry

EC1 -- Software subscription from US provider (e.g., Google Workspace) [T1]

Situation: Ukrainian company pays for cloud services from a US company (B2B), no PDV on invoice. Resolution: Reverse charge. Self-assess at 20% in Line 8/8.1. Register self-invoice in YERPN. Deduct in Line 12. Net = zero. Legislation: TCU Article 208

EC2 -- Export of goods to EU country [T1]

Situation: Ukrainian manufacturer exports grain to Germany. Customs declaration obtained. Resolution: Zero-rated under Article 195.1.1. Report in Line 4. No output PDV. Full input PDV refund available. Legislation: TCU Article 195.1.1

EC3 -- Sale of medicines at 7% [T1]

Situation: Pharmaceutical distributor sells registered medicines to a pharmacy, net UAH 500,000. Resolution: Line 2 = UAH 500,000. Line 2.1 = UAH 35,000 (7%). Legislation: TCU Article 193.1

EC4 -- Purchase of passenger car [T1]

Situation: Company purchases a sedan for management use, net UAH 1,000,000, PDV UAH 200,000. Resolution: Input PDV of UAH 200,000 is BLOCKED (Article 198.4). Vehicle capitalized at UAH 1,200,000. Legislation: TCU Article 198.4

EC5 -- Sale of sunflower seeds at 14% [T1]

Situation: Agricultural producer sells sunflower seeds to a processing plant, net UAH 2,000,000. Resolution: Line 3 = UAH 2,000,000. Line 3.1 = UAH 280,000 (14%). Legislation: TCU Article 193.1; 14% rate list

EC6 -- Tax invoice blocked by SMKOR [T2]

Situation: Supplier registers a tax invoice, but it is blocked by the monitoring system. Resolution: Buyer CANNOT claim input PDV until the invoice is unblocked. Supplier must submit explanations and documents to the regional commission. If unblocked, buyer claims input PDV in the period of unblocking. Flag for reviewer: track unblocking process. Legislation: TCU Article 201.16; CMU Resolution No. 1165

EC7 -- Goods destroyed by shelling [T2]

Situation: Warehouse with goods (input PDV previously claimed) is destroyed by Russian military attack. Resolution: Input PDV is NOT reversed under wartime provisions. However, the PDV amount cannot be refunded in cash -- it can only offset future liabilities. Documentation required: act of destruction, military administration confirmation. Flag for reviewer: confirm wartime provision applicability. Legislation: TCU Transitional Provisions; Law No. 2118-IX

EC8 -- Import of goods from China [T1]

Situation: Ukrainian retailer imports electronics from China. Customs declaration shows UAH 3,000,000 value, PDV UAH 600,000. Resolution: Import PDV paid at customs. Deductible in Line 11.1 = UAH 600,000. Also increases SEA PDV registration limit. Legislation: TCU Article 190, 206

EC9 -- Free supply of goods to Armed Forces [T1]

Situation: Company donates supplies (food, equipment) to the Armed Forces of Ukraine free of charge. Resolution: NOT a taxable supply under wartime provisions. No output PDV. Input PDV on the donated goods is NOT reversed. This is a specific wartime exemption. Legislation: TCU Transitional Provisions; Law No. 2120-IX

EC10 -- Credit notes (rozrakhunok koryguvannia) [T1]

Situation: Supplier issues an adjustment calculation (rozrakhunok koryguvannia) to correct a previous tax invoice. Resolution: Adjustment must be registered in YERPN. Buyer must confirm acceptance (for decreases). Affects output/input PDV in the period of registration. Both parties adjust their returns accordingly. Legislation: TCU Article 192

EC11 -- Services to foreign client (B2B export of services) [T1]

Situation: Ukrainian IT company provides software development services to a US client. Resolution: Place of supply is where the recipient is established (US) per Article 186.4. Supply is outside the scope of Ukrainian PDV. No output PDV charged. Input PDV on related costs is deductible. Legislation: TCU Article 186.4

EC12 -- Residential property rental [T1]

Situation: Company rents out apartments to tenants for residential use. Resolution: Exempt under Article 197.1.14. No output PDV. Input PDV on related costs is NOT deductible (Article 198.4). Legislation: TCU Article 197.1.14

EC13 -- SEA PDV insufficient balance [T1]

Situation: Company needs to register a tax invoice for UAH 500,000 PDV but SEA PDV account shows only UAH 300,000 balance. Resolution: Cannot register the invoice. Must either wait for incoming registered tax invoices (which increase the balance) or transfer UAH 200,000 to the SEA PDV Treasury account to top up the balance. Legislation: TCU Article 200-1

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Step 12: Reviewer Escalation Protocol

When a [T2] situation is identified, output:

REVIEWER FLAG
Tier: T2
Transaction: [description]
Issue: [what is ambiguous]
Options: [list the possible treatments]
Recommended: [which treatment is most likely correct and why]
Action Required: Qualified tax adviser must confirm before filing.

When a [T3] situation is identified, output:

ESCALATION REQUIRED
Tier: T3
Transaction: [description]
Issue: [what is outside skill scope]
Action Required: Do not classify. Refer to qualified tax adviser. Document gap.

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Step 13: Test Suite

Test 1 -- Standard domestic sale at 20%

Input: Ukrainian company sells IT services to a domestic client, net UAH 1,000,000, PDV UAH 200,000. Expected output: Line 1 = UAH 1,000,000. Line 1.1 = UAH 200,000. Output PDV reported.

Test 2 -- Sale of medicines at 7%

Input: Pharmaceutical company sells registered medicines, net UAH 300,000, PDV UAH 21,000. Expected output: Line 2 = UAH 300,000. Line 2.1 = UAH 21,000.

Test 3 -- Sale of sunflower seeds at 14%

Input: Agricultural producer sells sunflower seeds, net UAH 5,000,000, PDV UAH 700,000. Expected output: Line 3 = UAH 5,000,000. Line 3.1 = UAH 700,000.

Test 4 -- Export of goods, zero-rated

Input: Ukrainian manufacturer exports machinery to Poland, net UAH 10,000,000. Customs declaration obtained. Expected output: Line 4 = UAH 10,000,000. No output PDV. Input PDV refundable.

Test 5 -- Import of services, reverse charge

Input: Ukrainian company receives consulting from a UK firm, GBP 20,000 (approx. UAH 1,000,000). No PDV. Expected output: Line 8 = UAH 1,000,000. Line 8.1 = UAH 200,000 (20%). Line 12 = UAH 200,000. Net = zero.

Test 6 -- Passenger car purchase, blocked

Input: Company purchases sedan, net UAH 1,500,000, PDV UAH 300,000. Expected output: Input PDV UAH 300,000 BLOCKED. Vehicle capitalized at UAH 1,800,000.

Test 7 -- Import of goods

Input: Ukrainian retailer imports goods from Turkey. Customs value UAH 2,000,000, import PDV UAH 400,000. Expected output: Line 11.1 = UAH 400,000 (input PDV from customs).

Test 8 -- Donation to Armed Forces (wartime)

Input: Company donates UAH 500,000 worth of food to Armed Forces. Input PDV of UAH 100,000 was claimed. Expected output: No output PDV (wartime exemption). Input PDV of UAH 100,000 is NOT reversed.

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PROHIBITIONS [T1]

• NEVER allow input PDV deduction without a registered tax invoice in YERPN
• NEVER allow input PDV deduction on passenger vehicles (unless taxi/rental/emergency)
• NEVER skip reverse charge (self-assessment) for services received from non-residents
• NEVER treat Ukraine as an EU member state -- no intra-community supply rules apply
• NEVER register a tax invoice when SEA PDV balance is insufficient -- top up first
• NEVER confuse zero-rated (Article 195, with input recovery) with exempt (Article 197, without recovery)
• NEVER register import of goods via reverse charge -- Customs handles PDV on imports
• NEVER ignore the 15-day tax invoice registration deadline -- fines are significant
• NEVER apply the 14% rate to goods not on the specific agricultural list
• NEVER assume wartime provisions apply without confirming the specific provision and documentation [T2]
• NEVER compute any number -- all arithmetic is handled by the deterministic engine, not the AI
• NEVER process transactions involving temporarily occupied territories without qualified tax adviser [T3]

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Step 14: Invoice and Documentation Requirements

14a. Tax Invoice (Podatkova Nakladna) Detailed Requirements [T1]

Requirement	Details
Format	Electronic only (mandatory since 1 January 2017)
Registration	Must be registered in YERPN within 15 calendar days of the tax point
Mandatory fields	Supplier name, EDRPOU/RNOCPP, IPN; buyer name, EDRPOU/RNOCPP, IPN; date of supply; date of issuance; sequential number; description of goods/services; unit of measure; quantity; unit price (excluding PDV); PDV rate; PDV amount; total (including PDV)
Self-invoice	Required for reverse charge (import of services); supplier field shows non-resident details
Copies	Electronic original stored in YERPN; accessible to both parties
Correction	Via rozrakhunok koryguvannia (adjustment calculation); must reference original
Void	Cancelled invoices must still be registered as "cancelled" in YERPN

Legislation: TCU Article 201; Ministry of Finance Order No. 1307

14b. Adjustment Calculation (Rozrakhunok Koryguvannia) [T1]

Feature	Details
Purpose	Adjust a previously registered tax invoice (increase or decrease)
When required	Returns, price changes, errors, partial cancellation
Buyer confirmation	Required for adjustment decreases (buyer must accept in YERPN)
Deadline	Within 15 calendar days of the event triggering adjustment
Effect	Adjusts output PDV (seller) and input PDV (buyer) in the period of registration

14c. Advance Payment Invoicing [T1]

Event	Tax Point	Invoice Obligation
Advance received (before delivery)	Date of receipt	Tax invoice must be registered within 15 days
Delivery after advance	Date of delivery	Final tax invoice for remaining amount
Full prepayment	Date of receipt	Single tax invoice for full amount

Legislation: TCU Article 187

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Step 15: Record-Keeping and Reporting

15a. PDV Registers [T1]

Register	Description	Legal Basis
Register of issued tax invoices	All tax invoices issued (including adjustments)	Art 201.11
Register of received tax invoices	All tax invoices received (including adjustments)	Art 201.11
YERPN register	Central electronic register maintained by DPS	Art 201.10
Annexes to PDV return	Detailed tables (D1-D7) submitted with the monthly return	Ministry of Finance Order

15b. PDV Return Annexes [T1]

Annex	Content
D1	Detailed breakdown of tax invoices issued and received (decryption)
D2	Transactions not subject to PDV or exempt
D3	Adjustment calculations issued
D4	Adjustment calculations received
D5	Decryption of transactions with non-residents
D6	Summary of PDV refund calculations
D7	Not currently in use

15c. Document Retention [T1]

Document	Retention Period
Tax invoices (in YERPN)	1,095 days (3 years) from filing deadline
Customs declarations	1,095 days
Contracts and agreements	1,095 days
Bank statements	1,095 days
Accounting records	1,095 days (may be longer per accounting law)

Legislation: TCU Article 44.3

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2026 Changes

Change	Details	Effective
Electric vehicles	PDV exemption on import and sale of electric vehicles expired; standard 20% rate now applies to EVs	1 January 2026
Energy equipment import exemption	Extended until 1 January 2029; scope expanded to include wind turbines	Extended
Martial law provisions	Continue in effect as of April 2026; monitor for any changes	Ongoing

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Contribution Notes

This skill covers Ukrainian PDV as of April 2026. Ukrainian tax law is subject to frequent amendment, particularly during the period of martial law. Wartime provisions are temporary and may be extended, modified, or terminated at any time by the Verkhovna Rada. All rates, thresholds, and wartime provisions should be verified against the most recent legislation and DPS guidance before filing. A qualified Ukrainian tax adviser (podatkovyi konsultant) or auditor must validate all T1 rules before this skill is used in production.

A skill may not be published without sign-off from a qualified practitioner in the relevant jurisdiction.

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Disclaimer

This skill and its outputs are provided for informational and computational purposes only and do not constitute tax, legal, or financial advice. Open Accountants and its contributors accept no liability for any errors, omissions, or outcomes arising from the use of this skill. All outputs must be reviewed and signed off by a qualified professional (such as a CPA, EA, tax attorney, or equivalent licensed practitioner in your jurisdiction) before filing or acting upon.

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