Ukraine: Parliament advances VAT on e-commerce; Cabinet resubmits customs companion bill

Ukraine's parliament (Verkhovna Rada) on July 31, 2026, registered for consideration Bill No. 15460, a Customs Code amendment that would provide the customs and collection mechanics for a new value added tax (VAT) framework on cross-border sales of goods to individuals in Ukraine carried out via electronic interfaces. The substantive VAT rules themselves are contained in a separate Tax Code bill (No. 15112-d), which is already under consideration by the Verkhovna Rada; the two bills are intended to be adopted together as a package.

Background

On March 30, 2026, the Cabinet of Ministers of Ukraine submitted a draft law to Parliament proposing amendments to the Tax Code of Ukraine to introduce a VAT framework for cross-border sales of goods to individuals in Ukraine carried out via electronic interfaces (for example, online marketplaces and platforms). The proposal broadly followed international and EU approaches for low-value consignments and marketplace VAT (an IOSS-style deemed-supplier model), shifting responsibility for VAT collection on qualifying low-value imports from postal operators to electronic interface enterprises (including nonresidents), with a proposed effective date of January 1, 2027. Under that initial proposal, VAT would become chargeable when the platform received payment; the VAT base would be the total invoice value (determined, for nonresidents, in EUR or USD); platforms would not issue Ukrainian VAT invoices and would not recover input VAT on such sales; and the importation of goods sold under the regime would be VAT-exempt. Existing exemptions for noncommercial consignments (e.g., gifts up to €45) would be retained. For more information, read TaxNewsFlash.

The two bills

The reform is structured as a package of two bills intended to be adopted together:

• Bill No. 15112-d (Tax Code) – the operative VAT provisions. Registered May 7, 2026, this bill contains the substantive VAT rules: repeal of the €150 VAT exemption for marketplace goods (20% VAT from the first euro), the "electronic interface enterprise" deemed-supplier model for resident and nonresident platforms, and the VAT base, chargeability, currency, and invoicing/recovery rules. Official card.
• Bill No. 15460 (Customs Code) – the collection mechanics. Reapproved by the Cabinet on July 29, 2026, and registered July 31, 2026, this companion bill provides the customs formalities for goods moved in international postal and express consignments—declaration via special registers, exchange-rate rules, marketplace accounting/representation requirements, the special guarantee for the distance-sales scheme, and the transitional period. Official card.

The Ministry of Finance has stated that, together, these two documents create a comprehensive legal framework for a modern European model of taxation of distance sales of goods.

Unchanged core concept

The fundamental architecture is the same as the original proposal:

• Repeal of the €150 VAT exemption for commercial marketplace goods (20% VAT from the first euro)
• Shift of VAT liability from postal operators to the "electronic interface enterprise" (deemed-supplier model, including nonresidents)
• Retention of the €150 threshold for import duty purposes only
• Preservation of the €45 exemption for genuine noncommercial gifts between individuals
• Proposed effective date of no earlier than January 1, 2027

Key changes and clarifications in the resubmitted bill (No. 15460)

Compared with the initial March 30, 2026, proposal, the package introduces and clarifies the following:

• VAT collected at checkout. Under the main scenario, the buyer pays VAT at the point of purchase, with the amount displayed at checkout, avoiding separate contact with customs on arrival. (The initial proposal framed chargeability by reference to the platform's receipt of payment, without detailing checkout-level collection.)
• €100,000 financial guarantee (new). The marketplace, or its authorized Ukrainian intermediary, would be required to provide a financial guarantee equivalent to €100,000 to protect the budget where VAT is collected but not remitted. This requirement was not present in the initial proposal.
• Registration and Ukrainian representation. Foreign platforms ("electronic interface operators") would register with the Ukrainian customs system, obtain a special registration number, and submit information on goods sold; a nonresident must designate or may operate through a Ukrainian intermediary that registers with customs, submits the required data, and is responsible for the tax obligations.
• Customs clearance procedures now specified. Whereas the related Customs Code changes were undrafted at the time of the initial proposal, Bill No. 15460 sets out the customs clearance procedures for online purchases, the obligations of marketplaces, and the VAT payment mechanics, with information on goods, VAT charged, and financial security transmitted via electronic registers of international consignments.
• Non-registration fallback. If a platform does not register, VAT would instead be assessed and collected from the recipient via postal operators or express carriers, potentially resulting in longer processing times.
• Distance-selling opt-in. Foreign marketplaces may elect to operate under the "distance-selling rules," under which the tax liability arises when the buyer transfers money to the seller and the VAT/customs duty payer is a Ukrainian marketplace or a resident intermediary designated by the foreign platform. The taxpayer must keep separate records of distance-selling transactions, pay tax monthly, and submit reports to customs authorities even where no sales were made.
• First-year transition relief. During the first year of implementation, no penalties would be imposed for unintentional errors in VAT payment, provided the tax is paid in full.
• Personal-parcel restrictions dropped. Unlike earlier versions, the revised text does not impose restrictions on sending perfume, coffee, or tea in personal parcels.
• Relationship to EU parcel charges. The bill does not adopt the EU's fixed per-category handling charge on low-value parcels; its key operative provision is the 20% VAT rate.

Several aspects of the regime will continue to depend on the final adopted text and related secondary legislation.

For more information, contact a KPMG tax professional:

Philippe Stephanny | philippestephanny@kpmg.com

Chinedu Nwachukwu | chinedunwachukwu@kpmg.com

Denys Pyshniuk | dpyshniuk@kpmg.ua