On 2 June 2026, the State Tax Service of Ukraine reported a large-scale scheme for moving funds abroad involving more than 2,000 high-risk companies, which resulted in record amounts of penalty interest being charged for the non-return of foreign currency proceeds.
The Council first systematically analyzed the gaps between amounts assessed, agreed tax liabilities and actual budget revenues following tax audits — the so-called “tax gaps” — in its own-initiative investigation report “Tax Inspections: Inspect – do not suspect” in 2024.
At that time, we found that despite the increase in additional assessments following tax audits — from UAH 34 billion in 2017 to UAH 90 billion in 2021 and UAH 75 billion in 2023 — the amounts of agreed liabilities and actual budget revenues were several times lower than the amounts assessed, as shown in the chart.
Recently, we received and analyzed statistics for 2024–2025 from the State Tax Service of Ukraine. The data shows that although additional assessments nearly doubled during this period compared to 2023, only 4.2–4.5% of these amounts actually reached the budget — slightly over UAH 6 billion per year.
The figures also indicate an unusually high level of agreed monetary liabilities — those which businesses, for various reasons, accepted and did not subsequently challenge in court. At the same time, the higher level of agreed liabilities did not translate into higher actual budget revenues.
We discussed this issue with the State Tax Service at a meeting in May 2026 and received an explanation that most of the additional assessments following tax audits in 2025 were penalty interest charged as a result of audits of compliance with currency legislation regarding the non-return of foreign currency proceeds. These amounts were neither challenged nor paid. They have now become tax debt.
Thus, the record-high additional assessments of the past two years have neither significantly contributed to filling the budget nor created a deterrent effect for deliberate violators.
The Council stands ready to support the state in further improving tax and currency policy so that businesses operate under fair and uniform rules, and additional tax assessments actually reach the budget.
