The International Monetary Fund (IMF) has included in the Extended Fund Facility (EFF) program a new structural benchmark with a deadline of December 31, 2026, which calls for the submission to the Verkhovna Rada of specific rules to combat tax evasion under the simplified tax system.
According to the updated EFF Memorandum of Understanding, the new legislation is intended to address the issues of artificially splitting businesses to maintain preferential limits, manipulative switching between tax regimes, and the use of the simplified system to conceal actual employment relationships and evade taxes on wages and the Unified Social Tax (UST).
At the same time, IMF experts recommended revising the draft of the new Labor Code regarding the definition of employment, noting that the requirement to meet at least five of eight criteria to establish an employment relationship places an excessive burden of proof on regulatory authorities, whereas meeting three criteria is sufficient.
According to the memorandum, the fight against the shadow economy requires additional resources for all tax authorities; therefore, following the appointment of a new head of the State Customs Service (SCS) in April 2026, the government must ensure sufficient funding is available for the re-certification of all customs officials, which is scheduled to begin in mid-2026. In addition, the 2027 budget must provide sufficient funding for the State Customs Service (SCS), the State Tax Service (STS), and the Economic Security Bureau (ESB) to improve their ability to hire and retain qualified personnel.
In the document, the government highlighted the challenges of passing legislation in parliament but noted that it remains committed to eliminating the VAT exemption for sole proprietors, given its importance for combating the shadow economy, mobilizing revenue, EU accession, and attracting donor support. Although the government considers improving tax administration to be extremely important, it sees greater risks in this area than the Fund’s staff does, as administrative reforms could lead to revenue losses if they are not carefully planned and implemented.
As reported, the IMF Executive Board approved the first review of Ukraine’s four-year EFF program early Tuesday morning, allowing for the immediate disbursement of approximately $690 million in the second tranche; however, it noted the failure to meet several performance criteria and cautioned against backsliding on reforms. Taking the first tranche into account, total disbursements under the program—which has a total value of $8.1 billion and was approved in late February of this year—will amount to approximately $2.2 billion.
The updated Memorandum on Ukraine’s Economic and Financial Policies under the Extended Fund Facility (EFF) program with the International Monetary Fund (IMF), following the results of its first review, also includes seven new structural benchmarks, six of which are fiscal.
de-shadowing, IMF, Individual entrepreneurs, simplified system, TAX
