Draft Law No. 15111-d (DAC7) adopted in Ukraine: new reporting and taxation rules for income earned through digital platforms

On 9 June 2026, the Parliament of Ukraine adopted in the second reading Draft Law No. 15111-d On Amendments to the Tax Code of Ukraine and Certain Other Legislative Acts of Ukraine regarding the Introduction of International Automatic Exchange of Information on Income Derived through Digital Platforms and the Taxation of Such Income (the “Draft Law”), which aims to introduce in Ukraine the international automatic exchange of information on income derived through digital platforms.

This Draft Law was developed to implement the key provisions of the OECD Model Rules for Reporting by Platform Operators and EU Directive 2021/514 of 22 March 2021 (“DAC7”). Similar to DAC7, the Draft Law establishes rules for platform operators to report income of individuals earned through the use of such platforms. In addition, the Draft Law introduces a special tax regime for income of individuals earned through digital platforms.

The Draft Law is part of Ukraine’s preparation for implementing the Multilateral Competent Authority Agreement on Automatic Exchange of Information on Income Derived through Digital Platforms (the “DPI Multilateral Agreement”).

The new rules will enter into force in several stages:

• the general provisions on definitions and administration will enter into force on the day following publication of the respective law;

• the changes regarding the obligation of a platform operator, including non-resident operators, to register with the State Tax Service of Ukraine will apply from 1 November 2026, but not earlier than the date on which the competent authority of Ukraine joins the DPI Multilateral Agreement;

• the changes regarding the application of special tax rules to individuals’ income from reportable activities through digital platforms and the filing of special tax reporting will apply from 1 January 2027. 

Below are the key provisions of the Draft Law based on the version signed by the Chairman of the Parliament of Ukraine as of 12 June 2026. Please note that the Draft Law also introduces other changes unrelated to DAC7, which require separate analysis.

Implementation of DAC7

Categories of platform operators: reporting, qualified, excluded

• Separate categories of platform operators are defined:
  • reporting platform operators — resident operators and, in certain cases, non-resident operators that are required to submit an annual report on income of reportable sellers by 31 January of the year following the reporting year. The first reporting period is 2027;
  • qualified platform operators — mainly non-residents from jurisdictions that are parties to the DPI Multilateral Agreement. Such operators do not submit a report on income of reportable sellers in Ukraine if such information is already submitted in another jurisdiction and is subject to exchange with Ukraine, but they must register as platform operators by 1 January 2027;
  • excluded platform operators — operators that annually provide the controlling authorities with confirmation that they have no reportable sellers.

Categories of sellers and reportable activities

• Separate categories of individual sellers are defined:
  • reportable seller — an active seller that carries out a reportable activity or receives consideration for it, is not an excluded seller, and is resident in a DPI participating jurisdiction, including Ukraine, and/or rents out immovable property located there;
  • excluded sellers include, in particular, government and public entities, large lessors with more than 2,000 transactions per year, and small sellers with up to 30 sales and up to EUR 2,000 of income per year;

• Reportable activities include rental of immovable property, rental of vehicles, sale of goods, and provision of personal services through a platform.

Special tax regime for income earned through digital platforms

Platform operator as tax agent

• The tax agent of an individual seller is the platform operator, including a non-resident operator.

• Income of an individual seller is subject to taxation provided that such individual simultaneously meets certain requirements. Accordingly, platform operators will be required to collect information about individual sellers for reporting and tax withholding purposes, or to confirm grounds for not taxing the relevant income, for example, if the seller is an individual-entrepreneur.

Personal income tax rates and income thresholds

• Separate income thresholds and corresponding personal income tax rates are established:
  • income from the sale of goods not exceeding the equivalent of EUR 2,000 per year is not subject to personal income tax;
  • income not exceeding 834 minimum monthly wages per year, established as of 1 January of the reporting period, approximately UAH 7.2 million for 2026, is taxed at the 10% personal income tax rate;
  • income exceeding 834 minimum monthly wages per year is taxed at the 23% personal income tax rate.

• a phased reduction of rates after the end of martial law is envisaged.

• the relevant income amounts are exempt from military levy.

• the tax agent, i.e. the platform operator, is required to withhold tax on a monthly basis, while payment of tax to the budget may be made in foreign currency.

Procedure for withholding and paying tax

• Tax agents are required to file a simplified tax calculation by 31 January of the year following the reporting year.

PwC comment

We recommend that platform operators analyse the applicability of the rules to their activities and set up an approach to collecting information from sellers to ensure compliance with the new requirements.

Compliance with the new requirements will require operators to amend terms of use and agreements with sellers and will also affect the amount of income or payments to individuals. Collection of the necessary information may also take considerable time.

We recommend monitoring the moment when Ukraine joins the DPI Multilateral Agreement and following the publication of related by-laws by the Ministry of Finance of Ukraine.