Investment analysis by Ruslan Averin — originally published at averin.com.
The fine for failing to file a Ukrainian income declaration is 340 hryvnia. About eight dollars.
That number is the reason people misjudge this entirely. The declaration fine is trivial; what sits underneath it is not.
The actual structure of the exposure
| Violation | Charge |
|---|---|
| Declaration not filed | 340 UAH per violation |
| Repeated within the year | 1,020 UAH |
| Tax understated | 10% of the amount |
| Understatement found intentional | 25% |
| Paid late, under 30 days | 5% of the debt |
| Paid late, over 30 days | 10% |
| Interest (penya) | accrues on the debt |
| CFC report not filed | 332,800 UAH |
Read that as one line rather than eight: the unpaid tax comes back with a quarter added on top, plus a late payment charge, plus interest running from the original due date — and if a foreign company is anywhere in the picture, a separate six-figure fine that has nothing to do with whether any tax was owed.
The word that costs 15 points
The gap between 10% and 25% is the finding of intent.
Intent is not established by a confession. It is inferred from conduct: income received over several years and never declared, a structure that appears designed to obscure the recipient, statements that contradict data the authority already holds. A single missed year with a plausible explanation looks different from a pattern.
This is the practical argument for fixing an omission before it is raised with you rather than after. The same unpaid tax is materially cheaper when the correction is yours.
The assumption that stopped working
The old model was that foreign income was invisible unless something drew attention to it. Automatic exchange of financial account information ended that. Participating jurisdictions transmit account balances and income of Ukrainian tax residents to Ukraine on an annual cycle, unprompted.
The tax authority does not need to find the account. It receives a file. What it does need is a reason to look at yours, and a declaration that contradicts data already in hand is exactly that.
The realistic planning assumption for 2026: the foreign account is known, the crypto-to-fiat conversions through a bank are known, and the open question is only whether your filing matches.
The time limits
The general limitation period for assessments is 1,095 days from the filing deadline. It does not run where no declaration was filed at all — an unfiled year does not quietly age out the way a filed-but-wrong one does.
At larger amounts the matter stops being purely administrative and enters criminal territory, with thresholds tied to statutory indicators and mitigation available where the assessed amount is paid. That is a lawyer's conversation, not a filing one, and the way to stay out of it is arithmetic done three years earlier.
How I read it
The cost of non-declaration is not the fine. It is the interest and the penalty accruing quietly on a liability that does not expire, in a system that now receives your account data automatically.
For a Ukrainian investor with foreign holdings, the rational position is simple and slightly boring: file every year, including the loss-making ones and the empty ones, keep the acquisition records, and treat the certificate for any foreign tax credit as a task for autumn rather than for the week before the deadline.
The tax itself, at 14% on dividends and 23% on gains, was never the expensive part. Ignoring it is.
More market analysis by Ruslan Averin at averin.com.
