Ukraine: Digital platform reporting and withholding rules adopted

The Parliament on June 9, 2029, adopted law No. 15111-d, implementing the OECD’s digital platforms information exchange framework (DPI), as well as an income tax withholding requirement for platforms facilitating certain transactions. The OECD’s framework for the automatic exchange of information on income derived through digital platforms, implemented via the Multilateral Competent Authority Agreement on Automatic Exchange of Information on Income Derived Through Digital Platforms (DPI MCAA), allows tax authorities automatically exchange information on income earned by sellers through digital platforms. It is designed to ensure that jurisdictions receive standardized data on platform‑derived income so they can correctly tax their residents and combat tax evasion in the platform economy.

Reporting platform

Under the new rules, “reporting platforms” (reportable platform operators) are digital platforms whose operators (1) are Ukrainian residents, or nonresident organizations with a sufficient nexus to Ukraine (e.g., incorporated under Ukrainian law, effectively managed from Ukraine, or operating in Ukraine through a permanent establishment and not treated as “qualified operators”), and (2) enable reportable activities by sellers who are Ukrainian tax residents or who rent out real estate located in Ukraine, except for “qualified operators.” These platforms must register as platform operators in Ukraine and annually report detailed income information, unless another operator of the same platform has formally assumed full DPI reporting responsibility for those sellers before Ukrainian tax authorities. A “qualified operator” is an operator resident, registered or effectively managed in a foreign jurisdiction that has signed a DPI MCAA‑type agreement with Ukraine and whose competent authority exchanges a full set of DPI information with the Ukrainian tax authority; Ukrainian‑resident operators can never be treated as qualified operators.

Reportable sellers

“Reportable sellers” are active platform users (individuals or organizations) for whom a reportable platform operator must collect and report income information. A seller is reportable if, during the year, they carry out at least one reportable activity via the platform and are not an “excluded seller” (such as a government entity, a publicly traded company or certain very small/very large operators defined in the law), and they either (1) are tax resident in a jurisdiction that is party to the DPI MCAA or another qualifying agreement (including Ukraine), or (2) rent out immovable property located in such a jurisdiction.

Reportable transactions

A “reportable transaction” is any transaction carried out via a digital platform that falls within a reportable activity: (1) rental of immovable property (residential or nonresidential, including parking spaces) in Ukraine, (2) provision of personal services (online or offline, arranged through the platform), (3) sale of goods (non‑digital, tangible items), or (4) rental of means of transport, for which a seller receives consideration. All such transactions by a reportable seller during the reporting period are treated as reportable transactions and must be aggregated (by quarter) and included in the platform operator’s annual DPI report, irrespective of where the buyer is located or, for goods and services, where they are performed or delivered.

Due diligence requirements

Reportable platform operators must perform tax‑specific due diligence to identify reportable sellers and determine their tax residence. This includes collecting and verifying key data for each seller (name, address, tax identification number(s), date of birth or registration number, VAT number where applicable, and, for property rentals, the address and details of each listed property), using information already held by the platform, seller self‑certifications and reliable independent documents (e.g., identity documents, tax residency certificates), and—when available—state verification services for Ukrainian residents. Operators must keep all supporting records (including electronic records) for at least 5 years after the filing deadline for the relevant DPI report, and if a seller fails to provide requested information after reminders, the operator is required to terminate the relationship, block access to the platform or suspend payouts until the information is provided.

Income tax withholding requirements

A platform has to withhold Ukrainian income tax when it pays or credits income to an individual seller who is a Ukrainian tax resident, is not treated on the platform as a sole proprietor or other self‑employed person, and earns that income through “reportable” activities on the platform (renting out property, providing services, renting out vehicles, or selling goods). In such cases, the platform must usually take 10% tax out of the seller’s income and pay it to the Ukrainian budget by the 30th day of the next month. For sales of goods, the platform does not withhold tax on the first €2,000 of annual goods income per seller across all platforms; it only withholds 10% on any goods income above that amount. Separately from this withholding, if the seller’s total annual platform income exceeds 834 times the Ukrainian minimum wage, the excess is taxed at 23% in the seller’s annual assessment, with the 10% already withheld by platforms credited against that higher 23% liability.

Compliance requirements

In addition to the due diligence and withholding obligations, platform operators that qualify as reportable platform operators must collect and securely store key identification data for each reportable seller (such as name, address, tax ID, date of birth or registration number, VAT number where applicable, and, for property rentals, details of each listed property), together with transactional data (amounts of consideration by quarter, number and type of transactions, and any fees, commissions or taxes withheld). Using this data, platforms must submit an annual electronic DPI report to the Ukrainian tax authority by January 31 of the following year, in the prescribed format, listing all reportable sellers and their aggregated income and activity details for the previous calendar year, and must also provide each reported seller with an individual income summary so the seller can see what has been reported and use it for their own tax compliance.

The first DPI reporting period is the 2027 calendar year, so the first DPI report will be due in 2028; the exact 2028 deadline will be set by the Ministry of Finance, but the law says it cannot be earlier than January 31, 2028.

Nonresident operators must comply via a dedicated online portal, including for registration, reporting, payment of Ukrainian tax (in euros or U.S. dollars when allowed), and handling notices or audits. Failure to meet these compliance obligations can trigger substantial fixed and percentage‑based penalties and, in cases of persistent non‑registration, court‑ordered blocking of access to the platform in Ukraine.

For more information, contact a KPMG tax professional:

Philippe Stephanny | philippestephanny@kpmg.com

Chinedu Nwachukwu | chinedunwachukwu@kpmg.com

Oksana Olekhova | oolekhova@kpmg.ua

Denys Pyshniuk I dpyshniuk@kpmg.ua