On 30 September, Ukraine joined the international exchange of information on financial accounts based on the CRS standard. As a result, the provision of social benefits to refugees can be optimised, so that only those who really need it will receive assistance. Learn about the changes and categories of refugees who may lose their benefits

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On 20 March 2023, Law No. 2970-IX "On Amendments to the Tax Code of Ukraine and Other Legislative Acts of Ukraine Regarding the Implementation of the International Standard for the Automatic Exchange of Information on Financial Accounts" was adopted. Ukraine plans to conduct the first such exchange with other countries on 30 September this year. Read how this will affect social payments to Ukrainian refugees in this article.

What is currently known about the international exchange of financial data to be conducted by Ukraine?

The data exchange will be based on information for the second quarter of 2023. Subsequently, participating states will report annually for the previous calendar year.

Quite often, Ukrainian entrepreneurs attract foreign investments, which, of course, should be taken into account in financial reports. You can find out who invests the most in Ukrainian companies in this article.

What information will foreign authorities have access to based on the data obtained?

120 countries will have access to the data of the Ukrainian financial system, namely:

- open bank accounts of Ukrainians;

- participation in insurance and investment campaigns;

- regular receipts of funds to accounts (we are talking about profits from renting out real estate);

- income from the sale of real estate.

Based on the data, local authorities abroad may revise the grounds for social payments - only those in need will receive them. Each case will be considered individually.

The Ukrainian tax authorities will also have access to foreign accounts of their citizens, making the system much more open and transparent. For more details, please follow the link.

What categories of people will be considered in detail to determine the need for payments?

First of all, attention will be paid to the working-age population receiving social assistance in the countries that have granted asylum.

Will the data of women caring for a child and receiving payments from a Ukrainian husband also be reviewed?

Pension accounts will be checked by social services.

More information on how to use a Ukrainian bank card abroad can be found here.

Which categories of refugees will be deprived of payments?

First of all, people who conceal their income in Ukraine will be deprived of payments. If a large-scale fraud is detected, refugees will have to pay substantial fines. It should be remembered that after 30 September 2024, the authorities of each country connected to the CRS network will have access to information on property and accounts.

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What data is presented in the CRS report?

According to the General Standard for Reporting and Due Diligence on Financial Accounts (OECD publication, translated into Ukrainian), we provide a list of data that a reporting financial institution must provide.

For an individual:

1) Name;

2) Address;

3) Jurisdiction(s) of the individual;

4) TIN;

5) Date and place of birth.

For a legal entity:

1) Name;

2) Address;

3) Jurisdiction(s) of the individual;

4) TIN (EDRPOU) of the organisation;

5) Name of the reporting person;

2) Address of the reporting person;

3) Jurisdiction(s) of the reporting person;

4) TIN of the reporting person;

5) Date and place of birth of the reporting person.

For all categories:

1) account number;

2) name and identification number of the financial reporting institution;

3) account balance or value at the end of the reporting period;

4) account closing date (if applicable);

5) the total gross amount credited to the Holder during the reporting period (different for custody, deposit and other accounts).

How will the audit take place?

According to OBOZ.UA, quoting a tax consultant at the Kyiv Business Support and Development Centre, only the first stage of information exchange is expected to start on 30 September. This will include accounts with a balance of one million dollars or more and new accounts.

In general, the audits will take place in two stages:

▪️ 30 September 2024 - exchange of data on new accounts opened after 1 July 2023 and high-value accounts of individuals (over USD 1 million as of 30 June 2023);

▪️ on 30 September 2025 - on low-value accounts (less than USD 1 million as of 30 June 2023) and accounts of organisations with a balance or value exceeding USD 250 thousand.

As explained in the article, Ukrainians will receive a CRS-1 questionnaire, in which they will provide personal data, as well as indicate in which countries they have tax residency and what tax number they have in that country, Tomashevska says. In other words, in order for data from Ukraine to be sent to Germany, a Ukrainian must indicate his or her tax residence in Germany in the application form, as well as his or her TIN there.

If a person is found to have violated the law or knowingly provided false information, a fine of UAH 800,000 is imposed.

In addition, if the client's information changes (for example, address of residence or residency), he or she must notify the financial agent within 30 days. Ignoring this requirement gives the financial institution the right to unilaterally terminate business relations with the client.

Who can face problems?

The consultant explains that it is not so much Ukrainian taxes that can cause problems as European ones. For example, if a refugee received social assistance in one of the EU countries and was not entitled to it because of income in Ukraine, then after the exchange of information, this person may be fined.

As noted above, the checks currently affect a small proportion of Ukrainian citizens. 

You may also be interested in information on double taxation for Ukrainians. Read about the peculiarities of functioning, double taxation and filing a declaration in this article.

Want to know more? Read the latest news and useful materials about Ukraine and the world in the News section.

Ihor Usyk is the Head of Legal Department at Visit Ukraine

Financial interaction between tax and social services is a relatively new phenomenon for Ukrainians. Youcan contact VisitUkraine specialists for legal assistance . This way you can reduce the risks of financial losses when travelling abroad.

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