On 22 October 2026, the President of Ukraine signed Law of Ukraine No. 4903-IX (the Law), which introduces new rules for taxing income earned by individuals through digital platforms, establishes tax obligations for platform operators, and provides for the international automatic exchange of tax information under the DAC7 standard. The Law also introduces changes to the taxation of rental income and land tax.
1. Taxation of Income Earned Through Digital Platforms
As of 1 January 2027, special rules will apply to income earned by individuals from activities carried out through digital platforms, including:
the sale of goods through online marketplaces;
the rental of residential and non-residential real estate, as well as parking spaces;
the rental of vehicles; and
the provision of personal services, including repair, transportation and freelance services.
Importantly, these rules concern activities carried out through digital platforms. An ordinary transfer of funds between individuals does not, in itself, automatically trigger the application of this tax regime.
The Law introduces a special tax regime for the relevant income earned by individuals.
Personal income tax (PIT) rate of 10% will apply, subject to compliance with the requirements of the special tax regime and within the annual threshold equal to 834 times the minimum monthly wage established by law as of 1 January of the relevant tax year; or
PIT rate of 23% will apply to the amount exceeding the above threshold or in other cases specified by the Law, including failure to comply with the requirements of the special tax regime.
No additional military levy will be payable on income taxed under these special rules.
At the same time, the Law establishes a special rule for individuals selling their own second-hand personal belongings through digital platforms.
The Law provides for a tax-exempt threshold of up to EUR 2,000 per year, subject to the conditions specified therein. In addition, the Law establishes criteria under which a seller may qualify as an excluded seller for the purposes of platform operators' reporting obligations.
In particular, the determination of whether a seller qualifies as an excluded seller takes into account the number of sales, the total amount of consideration received, and the absence of other reportable activities carried out through the platform.
2. Digital Platform Operators as Tax Agents
One of the key innovations is the assignment of tax agent functions to digital platform operators in respect of the relevant income earned by individuals.
Depending on the conditions established by the Law, platform operators will be required to:
register with the State Tax Service of Ukraine (the STS);
collect information about sellers and their activities carried out through the platform;
provide the tax authorities with information about the relevant sellers and the income they receive;
withhold and remit PIT to the state budget in the cases provided by the Law; and
submit reports on income earned through the platform.
Platform operators must register with the STS by 1 January 2027. The first reporting period under the new rules will be the 2027 calendar year.
These requirements will apply to both Ukrainian and certain foreign platform operators, depending on the criteria established by law.
The Law defines a digital platform as any software, including a website, part of a website or applications (including mobile applications), that is accessible to users and enables sellers to connect with other users to carry out reportable activities directly or indirectly for such users. The activities facilitated by the platform may also include the collection, calculation and payment (crediting) of remuneration for reportable activities.
Accordingly, digital platforms may include, in particular, online marketplaces (OLX, Prom), ride-hailing services (Uber), delivery services, real estate and vehicle rental platforms, as well as platforms for providing personal services. However, the final assessment depends on the specific business model of the service.
3. International Automatic Exchange of Information: The DAC7 Standard
The Law establishes the legal framework for the international automatic exchange of information on income earned through digital platforms.
Under the relevant international mechanisms, the STS will be able to obtain information on income earned by Ukrainian tax residents through foreign platforms and transmit the relevant information to foreign competent authorities.
The exchange of information will cover the categories of activities specified by law, including the sale of goods, the provision of personal services, and the rental of real estate and vehicles.
4. Other Changes
As of 23 October 2026, the Law reduces the PIT rate applicable to income earned by individuals from renting out residential and non-residential real estate from 18% to 5%.
This change is not limited to rentals arranged through digital platforms. Individuals who rent out real estate directly to tenants, outside digital platforms, may also apply the new rules, provided that the applicable legal requirements are met.
The Law also provides for an exemption from land tax for land plots on which real estate destroyed as a result of the armed aggression of the Russian Federation was located. A key condition is that the relevant information must be recorded in the Register of Damaged and Destroyed Property.
This provision entered into force on 23 October 2026 and applies from 1 January 2026.
5. Practical Recommendations for Businesses and Individuals
In light of the changes introduced by the Law, we recommend that:
Individuals selling goods or providing services through digital platforms assess the nature of their activities, the amount of income earned, and their eligibility for the special tax regime.
Property landlords assess whether the 5% PIT rate can be applied to rental income as of 23 October 2026.
Digital platform operators (both Ukrainian and foreign) assess their registration obligations with the STS, establish procedures for collecting and verifying seller information, and prepare to fulfil their tax agent obligations.
Businesses operating through foreign digital platforms take the forthcoming international exchange of tax information into account when assessing their tax risks.
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