Ukraine: Proposed changes to VAT collection on low-value imports for electronic interface enterprises

The Cabinet of Ministers of Ukraine on March 30, 2026, submitted a draft law to Parliament proposing amendments to the Tax Code of Ukraine to introduce a valued added tax (VAT) framework for cross‑border sales of goods to individuals in Ukraine carried out via electronic interfaces. The proposal broadly follows international approaches adopted for low‑value consignments and digital marketplaces, including models implemented in the European Union.

If enacted, the amendments would shift the responsibility for VAT collection on qualifying low‑value imports from postal operators to electronic interface enterprises (including certain intermediaries). This obligation would apply to both resident and nonresident platforms facilitating sales to Ukrainian consumers. The law is proposed to become effective on January 1, 2027.

Several aspects of the regime remain unclear, as the related amendments to the Customs Code of Ukraine have not yet been drafted or published, resulting in an incomplete understanding of the proposed changes to the Tax Code of Ukraine as well.

A summary of the current proposal is as follows:

Effective date and implementation

The proposed amendments would take effect on January 1, 2027. The Cabinet of Ministers and other competent authorities would be required to adopt and update secondary legislation within six months of the law becoming effective.

Scope of transactions

The draft law would apply to the sale of non‑excisable goods sold under cross‑border consumer sales arrangements, where the goods are imported into Ukraine in accordance with the Tax Code and Customs Code, purchased by individual consumers through an electronic interface, and shipped in consignments with a total invoice value not exceeding €150.

For these transactions, the place of taxation would be deemed to be Ukraine, determined by the location of the goods at the moment transport or dispatch to the individual recipient is completed. As a result, such sales would fall within the scope of Ukrainian VAT. The law expressly treats these sales as taxable for Ukrainian VAT purposes, notwithstanding that the physical importation of the goods is carried out by postal operators or express carriers.

Marketplace VAT liability

Under the proposed amendments, the “electronic interface enterprise” facilitating the sale would be responsible for calculating and remitting Ukrainian VAT. When the electronic interface enterprise is a nonresident, an intermediary appointed by the platform may also be treated as jointly responsible for fulfilling the VAT obligation at the level of the electronic interface.

VAT base and currency

For qualifying cross‑border consumer sales, the VAT base would be the total invoice value determined in accordance with the Customs Code. When the electronic interface enterprise is a nonresident, the tax base and VAT amount may be determined in a foreign currency, specifically the euro or U.S. dollar. Exchange rates for VAT determination purposes would follow the rules set out in the Customs Code of Ukraine.

Timing of VAT liability

For transactions covered by the proposed regime, VAT would become chargeable on the date the electronic interface enterprise receives payment from the customer.

Invoicing and VAT expense recovery

Electronic interface enterprises operating under the new consumer sales regime would not be required to issue Ukrainian VAT tax invoices for these transactions and would not be entitled to recover VAT expenses in respect of such sales.

Exemptions

The draft law would exempt from VAT the importation of goods purchased under the proposed regime, provided the goods are non‑excisable and sold to individuals.

Existing VAT exemptions for non‑commercial consignments, such as gifts with a value not exceeding €45, would be retained, subject to applicable quantity and nature restrictions.

For more information, contact a KPMG tax professional:

Philippe Stephanny | philippestephanny@kpmg.com

Chinedu Nwachukwu | chinedunwachukwu@kpmg.com

Denys Pyshniuk I dpyshniuk@kpmg.ua