From 1 October 2024 Ukraine launches a special regime for taxpayers with a high level of voluntary tax compliance, informally branded as the “white business club”. The mechanism is based on Law No. 3813-IX, which amends the Tax Code to reward transparent businesses with easier tax administration during martial law.
Who can join the “white business club”
The State Tax Service will include legal entities and individual entrepreneurs in a special List of high-compliance taxpayers if they simultaneously meet a number of basic requirements. In simplified form, the business must:
- Have no significant tax debt or arrears on other controlled payments, and any minor debt must be cleared within 30 days
- Have no arrears, penalties or fines on the payment of the unified social contribution (ESV)
- Have no systemic violations of reporting obligations, including transfer pricing and CFC reporting
- Have no tax notifications regarding breaches of export/import settlement deadlines over the last 12 months
- Not be classified as a “risky VAT payer” by the tax authorities
- Not be in the process of liquidation or bankruptcy
- Have no sanctions imposed on the company, its founders or ultimate beneficial owners
- Have no founders/UBOs who are citizens or tax residents of the aggressor state (with narrow exceptions for veterans), and no key owners whose place of residence is in such a state
- Not have changed its main type of economic activity in the state register during the last 12 consecutive months
Only those taxpayers that comply with all of these baseline conditions can be assessed against the more detailed quantitative criteria of the Tax Code.
Key quantitative criteria by taxpayer category
For each category of taxpayers, the Tax Code sets specific benchmarks that must be at least equal to or higher than the average figures for the relevant sector and region. In general this means:
- Legal entities on the general regime: the level of corporate profit tax and VAT paid over the last reporting periods must be at or above the sector average; average monthly salary per employee over the last four periods must be at least 1.1 times the average wage in the same sector and region, with at least five employees on staff.
- Diia City residents: the level of taxes paid to the consolidated budget must meet or exceed the average among Diia City companies.
- Legal entities on the simplified regime (group 3): overall tax payments to the consolidated budget and average wages must be at or above sector averages, again with at least five staff.
- Legal entities on the simplified regime (group 4 – agricultural producers): the difference between the minimum tax liability and actually paid taxes, fees and land rent must be negative (i.e. they pay at least the minimum); VAT payments and wages must meet sector averages, and land area and tax payments must be properly declared and paid.
- Entrepreneurs (FOP) on the general regime: the level of VAT and personal income tax paid must be at or above the sector average; average wages to employees must be at least 1.1 times the regional sector average.
- FOP on the simplified regime (group 3): annual declared income should exceed UAH 5 million; tax payments to the consolidated budget and average wages must meet or exceed the sector averages.
Newly registered taxpayers can be added to the List not earlier than one calendar year from the date of registration and only after they build a transparent tax history that can be compared with sector benchmarks.
How the list is formed and updated
The State Tax Service will form and approve the List of high-compliance taxpayers four times a year – by the last working day of March, May, August and November. Based on tax reporting data and information from other state bodies, the tax authorities calculate the required indicators and compare them with average values across Ukraine and by sectors.
The approved List is published on the official website of the State Tax Service, while individual companies and entrepreneurs are notified about their inclusion or exclusion through their electronic taxpayer cabinet. Taxpayers may also submit a notice refusing publication of their data, although in practice this could send mixed signals to partners and banks.
Why it matters for business and investors
Membership in the “white business club” is designed to become a reputational and practical asset. High-compliance taxpayers can expect, among other advantages, a moratorium on most documentary tax audits, shorter deadlines for VAT refund checks and individual tax consultations, and a dedicated compliance manager within the tax authority.
For Ukrainian and foreign investors this creates a visible segment of businesses that not only operate transparently, but also enjoy more predictable tax administration. For companies planning long-term projects in Ukraine, aligning their tax and HR policies with the criteria of the “white business club” can become part of a broader strategy to de-risk operations and signal reliability to partners, banks and international donors.
