From January through September 2026, 20,364 enforcement proceedings were initiated in Ukraine to collect tax debts from companies. The largest number of new proceedings involved companies in the wholesale trade, agriculture, and construction sectors.
This is evidenced by the results of a study by Opendatabot, published on November 9, 2026, based on information from the Unified Register of Debtors.
According to analysts, the number of new enforcement proceedings over the first nine months of this year nearly matched the total for all of 2021, when 20,687 such cases were opened.
By comparison, 14,829 proceedings were initiated in 2022 to collect corporate tax debts, 22,227 in 2023, 26,100 in 2024, and 26,847 in 2025.
Thus, in the first nine months of 2026, the number of new proceedings already accounted for approximately 76% of the total for the entire previous year.
The largest number of new proceedings was registered against companies whose primary business activity is wholesale trade. This sector accounted for 4,249 proceedings, or 20.9% of the total.
Agriculture ranked second with 1,814 proceedings, accounting for 8.9% of the total.
Construction ranked third, with 1,521 proceedings, or 7.5%.
The top five sectors with the highest number of new proceedings also included retail trade, with 808 cases, and real estate transactions, which accounted for 803 proceedings.
In addition, 726 proceedings were opened against land and pipeline transportation companies, 590 in the food service sector, 548 in civil engineering, and 522 in warehousing.
In total, the five economic sectors with the highest number of proceedings accounted for 9,195 cases, or 45.2% of all new proceedings.
At the same time, these statistics do not mean that enterprises in these sectors have the largest amounts of tax debt. The study reflects the number of enforcement proceedings, not the amount of funds subject to collection.
According to Opendatabot, as of October 19, 2026, a total of 36,409 enforcement proceedings in favor of the State Tax Service remained active.
This is approximately 1% more than in early December 2025, when there were 36,063 such proceedings.
At the same time, the scale of tax debt among Ukrainian businesses is significantly greater than the number of companies subject to enforcement proceedings.
According to a separate Opendatabot study, as of July 1, 2026, 218,731 companies had tax debts, and their total debt amounted to 263.32 billion UAH.
In the first half of the year, the number of companies with tax debts increased by 3%, while the total amount of debt rose by 4%.
At the same time, not all tax debts are referred for enforcement. The initiation of enforcement proceedings is a separate stage of the collection process, so the total number of companies with tax debts cannot be directly compared to the number of enforcement proceedings.
You can check whether there are any relevant proceedings against a specific company through the Unified Register of Debtors.
Sources: Opendatabot, study dated November 9, 2026; Opendatabot, study on tax debts dated September 7, 2026.
BUSINESS, CONSTRUCTION, DEBT, TAX, TRADE
The Myrhorod Bakery Complex No. 1 ranked first among Ukrainian enterprises in terms of the number of active enforcement proceedings aimed at collecting tax debts. As of October 19, 2026, 80 such proceedings remained open against the company.
This is according to a study by Opendatabot, published on November 9, 2026, based on data from the Unified Register of Debtors.
According to analysts, at the end of 2025, there were 79 active enforcement proceedings registered against the Myrhorod Bread Products Plant No. 1. Thus, over the comparable period, their number increased by one.
At the same time, among the companies that made it into the current top ten by number of active cases, the Rivne Automobile Repair Plant recorded the largest increase.
While the company had no active proceedings in the relevant sample at the end of 2025, as of October 19, that number had reached 43.
At the Zhytomyr Regional Road Administration, the number of active cases increased from 19 to 42.
Another significant increase was recorded for the Makharintsi Agricultural Firm, where the number of active cases rose from 22 to 34.
At the company “Bioresursservice,” this figure rose from 21 to 31 proceedings.
Separately, Opendatabot identified the companies against which the largest number of new enforcement proceedings for the compulsory collection of tax debts were initiated between January and September 2026.
Agrofirma Makharintsi topped the list with 32 cases opened against it over the nine-month period.
In second place was the Pervomaisky Granite and Crushed Stone Quarry with 29 new cases.
Third place went to the “Pryluky” Oil Extraction Plant, with 23 proceedings opened against it.
Next were the “Praktika” Educational Complex with 20 proceedings and the Verkhovyna Road Maintenance Division of the Ivano-Frankivsk Regional Road Administration with 19.
In addition, 17 new investigations were recorded for each of the following companies: “Zhitlovik,” “Vizavi,” “Ukrainian Advertising Factory,” and “Das-Group.”
Among the companies against which 16 new enforcement proceedings were opened are the “Burshtynsky” Fisheries Enterprise, “Shepetivkagaz,” “Dniproplastmas,” and the construction firm “MZhKBud.”
As of October 19, 2026, a total of 36,409 active enforcement proceedings in favor of the State Tax Service remained in Ukraine.
In early December 2025, this figure stood at 36,063 proceedings. Thus, the number of active cases increased by 346, or approximately 1%.
At the same time, 20,364 new enforcement proceedings were initiated during the first nine months of 2026.
The difference between the number of proceedings initiated during a given period and the change in the total number of active cases is explained by the fact that, over the course of the year, some previously initiated proceedings may be concluded or terminated on other grounds provided for by law.
However, the existence of multiple enforcement proceedings against a single enterprise does not mean that the company has a corresponding number of separate tax liabilities or the largest amount of debt.
Furthermore, the registry data does not allow for determining the amount of tax debt for each of the listed companies based solely on the number of proceedings.
According to separate data from the State Tax Service, previously analyzed by Opendatabot, as of July 1, 2026, a total of 218,731 Ukrainian companies had tax debts amounting to 263.32 billion UAH.
This indicates that the number of companies with tax arrears significantly exceeds the number of companies subject to enforcement proceedings.
Information about enforcement proceedings against a specific company can be checked via the Unified Register of Debtors using the EDRPOU code.
Sources: Opendatabot, study dated November 9, 2026; Unified Register of Debtors; Opendatabot, study on total tax arrears dated September 7, 2026.
In Kyiv and Dnipropetrovsk Oblast, 8,072 enforcement proceedings were initiated in the first nine months of 2026 to collect tax debts from companies, accounting for 39.6% of the total number of such proceedings in Ukraine.
This is according to a study by Opendatabot, published on November 9, 2026, based on information from the Unified Register of Debtors.
In total, 20,364 enforcement proceedings were initiated in Ukraine from January through September of this year to collect tax debts from companies.
Kyiv led in the number of new proceedings, with 4,160 cases registered, or 20.4% of the national total.
Dnipropetrovsk Oblast ranked second with 3,912 proceedings, accounting for 19.2%.
Significantly fewer new proceedings were recorded in Kyiv Oblast (1,352), Odesa Oblast (1,162), and Ivano-Frankivsk Oblast (896).
Thus, these five regions accounted for 11,482 new enforcement proceedings, or 56.4% of the total for the first nine months of 2026.
At the same time, the regional distribution of all active proceedings differs somewhat from the statistics on new cases.
According to Opendatabot, as of October 19, 2026, the highest number of active proceedings for the collection of corporate tax debts was registered in Dnipropetrovsk Oblast—6,777.
Kyiv ranked second with 4,652 active proceedings.
Next were the Kharkiv region with 2,036 cases, the Ivano-Frankivsk region with 1,997, and the Kyiv region with 1,820.
In total, the five regions with the highest number of active proceedings accounted for 17,282 cases, or 47.5% of the national total.
However, the highest number of cases does not necessarily indicate the highest level of tax debt among enterprises in the respective region.
In particular, according to another Opendatabot study, as of July 1, 2026, the largest amount of tax debt was concentrated in Kyiv—96.06 billion UAH.
In the capital, there were 58,056 companies with tax debts, or approximately 27% of all debtor companies in the country.
In the Dnipropetrovsk region, 17,042 companies had tax debts totaling 23.37 billion UAH.
In the Kharkiv region, 15,202 debtor companies were registered, with a total debt of 10.56 billion UAH.
Thus, Kyiv remains the largest hub for tax debt in terms of both the amount owed and the number of debtor companies, while the Dnipropetrovsk region leads in the number of active enforcement proceedings.
According to Opendatabot, the total amount of tax debt owed by Ukrainian companies as of July 1, 2026, was 263.32 billion UAH.
At the same time, these indicators reflect different stages of tax administration and different observation dates. Data on total debt cannot be directly equated with the number of enforcement proceedings aimed at its collection.
Sources: Opendatabot, analysis of enforcement proceedings as of November 9, 2026; Opendatabot, regional statistics on tax debts as of September 7, 2026.
The State Tax Service of Ukraine (STS) has reminded the public of the need to tax tips received by employees of restaurants, cafes, bars and other service establishments. Regardless of how the money is received, such income is subject to an 18% personal income tax (PIT) and a 5% military levy, the agency’s press service reported on November 4, 2026.
Thus, the total tax burden on tips amounts to 23%, and for every UAH 1,000 received, an employee must pay UAH 230 to the state.
The STS explained that the taxation procedure depends on whom the customer transfers the money to: directly to the employee or to the establishment, which subsequently pays it to the staff.
If a restaurant or cafe customer leaves a tip via a QR code linked to the personal bank card of a waiter or another employee, this money is considered the employee’s personal income.
In this case, the establishment does not act as a tax agent, and responsibility for declaring and paying taxes rests directly with the recipient of the funds.
In particular, the employee must independently calculate the total amount of tips received during the year, report it in the annual tax return and pay the corresponding taxes.
According to the STS clarification, income received in the form of tips in 2026 must be declared by May 1, 2027, while personal income tax and the military levy must be paid by August 1, 2027.
For example, if a restaurant employee received UAH 100,000 in tips directly to their personal bank card during the year, the total tax liability would amount to UAH 23,000, including UAH 18,000 in personal income tax and UAH 5,000 in military levy. After paying taxes, the employee would have UAH 77,000 remaining.
A different procedure applies when a customer pays a tip through a restaurant’s payment terminal together with the main bill or transfers it to the bank account of a company or an individual entrepreneur.
In this case, the establishment must record the funds received in its accounts and, when paying them to employees, withhold and transfer 18% personal income tax and a 5% military levy to the state budget.
An employee who receives such payments after taxes have already been withheld does not need to declare them additionally merely because they were received as tips.
The tax service also pointed out that regular tips for services provided cannot be considered tax-exempt gifts.
This rule applies even when the customer indicates “thank you,” “for coffee” or similar wording in the payment description of a bank transfer.
Therefore, the name of the payment itself does not change its tax status if the funds are actually remuneration for services.
The STS recommends that service sector employees retain bank statements and keep records of tips received so that they can correctly determine the amount of income subject to declaration at the end of the year.
At the same time, the legislation does not require a separate special register of tips to be maintained. Employees may independently record the relevant receipts, indicating the date and amount of each payment.
Such record-keeping will also make it possible to distinguish tips from other transfers to a personal bank card, including debt repayments, transfers from relatives and other receipts that may be subject to different tax treatment.
At the same time, the tax authorities emphasize that the method of transferring tips does not affect the obligation to pay taxes on them. The same rules apply to cashless transfers through QR codes and payment terminals as well as to tips received in cash.
For the restaurant business, the key issue remains organizing the accounting of tips and determining the party responsible for paying taxes, while for employees, it is the need to provide documentary evidence of the income received.
At the same time, the STS announcement of November 4 is a clarification of the existing taxation procedure, not the introduction of a new separate tax on tips.
Source: State Tax Service of Ukraine
Vietnam plans to introduce a special visa for highly qualified foreign specialists (the Vietnam Talent Visa), which will provide for a simplified process for obtaining residence permits, exemption from the requirement to obtain a work permit, and preferential conditions for family members. At the same time, it is proposed to exempt specialists involved in strategic projects from paying personal income tax for five years.
The Ministry of Public Security released the corresponding draft resolution of the National Assembly of Vietnam on October 16, 2026, for public comment.
The legislative initiative consists of 16 articles and aims to attract foreign experts, scientists, researchers, technology entrepreneurs, and other highly qualified specialists to implement strategic state programs, investment projects, and the development of an innovative economy.
The document applies not only to foreigners but also to Vietnamese citizens and members of the Vietnamese diaspora living abroad.
What benefits does the talent visa offer?
According to the draft, foreign specialists who meet the established criteria will be able to obtain a special visa and a corresponding temporary residence card.
Provisions are made for extending the duration of stay and changing the purpose of residence in accordance with immigration law.
Visa holders will be permitted to work simultaneously at multiple companies, research institutions, or government organizations without having to obtain a separate work permit for each employer.
When changing jobs, foreign specialists will not need to reapply for their current visa.
These simplifications will also apply to family members. Spouses and children under the age of 18 will be able to obtain UĐ2 visas and the corresponding temporary residence permits.
In addition, the state must ensure favorable conditions for the residence and education of the children of foreign specialists.
Five-Year Tax Holiday
One of the key provisions of the legislative initiative is a five-year exemption from personal income tax.
The exemption will apply to the salaries and bonuses of qualified specialists and the employees they recruit who perform strategic tasks.
It is proposed that the five-year period be calculated from the date the relevant income is earned.
At the same time, tax incentives will be available not only to specialists working in government agencies but also to employees of private companies involved in the implementation of strategic projects.
Separate incentives are provided for employers. Companies that hire qualified specialists to carry out strategic tasks will be able to additionally include in their tax-deductible expenses an amount equivalent to 50% of the salaries and bonuses actually paid to such employees.
Thus, the total amount of labor costs that can be taken into account when determining taxable income will potentially amount to 150% of actual payments.
Vietnam plans to allocate approximately 0.1% of GDP annually to talent development
The government also proposes establishing a special funding mechanism for programs aimed at attracting and developing highly qualified personnel.
It is planned to allocate approximately 0.1% of GDP annually for these purposes as part of the overall funding for science, technology, innovation, and digital transformation.
Priority will be given to projects of strategic importance to the country’s economy, particularly in the fields of high technology, scientific research, digitalization, and the modernization of production.
At the same time, the proposed selection system calls for an assessment of actual professional achievements and specialists’ ability to perform specific tasks.
Possession of a scientific degree, an academic title, or extensive professional experience will not be a mandatory requirement, except in cases where such requirements are explicitly stipulated by law for a specific type of activity.
According to the drafters, this will make it possible to attract not only renowned scientists but also young technology entrepreneurs, engineers, and developers of innovative products.
What the New Rules Will Mean for Foreign Investors
The proposed changes could increase Vietnam’s appeal to international technology companies, research and development centers, and enterprises implementing high-value-added investment projects.
Simplifying the hiring process for foreign experts and allowing them to work with multiple organizations simultaneously could reduce administrative costs for businesses and facilitate technology transfer.
At the same time, the proposed program is not a universal visa for digital nomads or an automatic pathway to obtaining a residence permit through real estate purchases.
Its main goal is to attract specialists to specific strategic programs and projects identified in accordance with national priorities.
The resolution has not yet been adopted. Once the public consultation period concludes, the document is to be reviewed by the National Assembly of Vietnam. The final selection criteria, application procedures, and validity periods for special visas will depend on the approved legislation.
Vietnam is one of the Southeast Asian economies actively attracting foreign investment in manufacturing, electronics, digital technologies, and infrastructure. In recent years, the country has been developing special support mechanisms for investors and highly qualified professionals with the aim of modernizing the economy and enhancing its international competitiveness.
The Italian government has proposed introducing, effective January 1, 2027, a tax on unrealized capital gains on financial assets for high-net-worth individuals who transfer their tax residency outside the country. The rate of the so-called “exit tax” will be 26%, and the new rules will apply to investors with relevant assets valued at EUR800,000 or more.
The relevant provisions are contained in Article 17 of the draft law on Italy’s 2027 state budget, approved by the government of Prime Minister Giorgia Meloni. The document received the necessary approval from Italian President Sergio Mattarella on October 30 and was submitted to Parliament for consideration.
According to the bill, the new tax will apply to individuals who have been residents of Italy for at least six of the last ten tax years and have decided to transfer their tax residency to another country.
A mandatory condition is the possession of financial assets and property rights subject to the relevant provision, with a total value of at least EUR800,000. However, taxation will apply only in cases where, following the change in residency, Italy loses the right to tax the corresponding investment income.
The tax will be levied not on the total value of the assets, but on the accumulated gains that the investor has not yet received from their sale.
Specifically, this refers to the increase in the market value of shares, equity interests in companies, securities, and other financial instruments. To determine the tax base, the positive difference between the market value of the assets and their tax basis at acquisition will be taken into account.
For example, if an investor purchased a portfolio of securities for EUR 700,000, and at the time the tax base is determined, its value has risen to EUR 1 million, the unrealized gain will amount to EUR 300,000. At the standard rate of 26%, the tax amount will reach EUR 78,000, even if the investor has not actually sold the assets.
At the same time, a preferential regime applies to income from certain government bonds. Only 48.08% of the corresponding profit will be included in the tax base, resulting in an effective rate of approximately 12.5%.
The standard deadline for paying the exit tax is 180 days from the date the change in tax residency takes effect.
However, for individuals relocating to European Union countries or to countries with which Italy has relevant tax cooperation agreements, a payment deferral is available.
To qualify, the investor must pay an advance equal to 50% of the calculated tax and provide a financial guarantee.
When moving to another EU country, the deferral may apply for up to five tax periods, and for other countries that meet the established conditions, up to ten.
If the assets are not sold during this time, the tax liability will be extinguished, and any overpaid amounts will be refunded. Similar provisions apply in specific cases of inheritance of assets or an investor’s return to Italy.
The new system will also apply to certain types of nonprofit associations and organizations that transfer their tax residency abroad.
According to estimates by the Italian Ministry of Economy and Finance, revenue from the new tax will amount to approximately EUR3.37 million in 2027 and EUR6.74 million annually from 2028 to 2031. Starting in 2032, the net budgetary impact, taking into account the expected refund of a portion of the payments, is estimated at EUR 3.37 million per year.
Italy is effectively proposing to extend to private investors the tax mechanism applicable upon a change in tax residency, which previously applied to companies and entrepreneurs.
A similar mechanism is already in place in France, where taxation of unrealized gains upon a change in tax residency applies provided that the relevant financial assets exist and the conditions established by law are met.
The proposed changes may be significant for international investors, owners of corporate assets, and high-net-worth foreigners who use Italy as a country of long-term tax residency.
In recent years, Italy has attracted high-net-worth foreigners through a special fixed-tax regime for foreign income. For new participants in this regime, starting in 2026, the annual payment will be EUR 300,000 instead of the previous EUR 200,000.
The introduction of the exit tax may affect the tax planning of such investors, especially if they are considering relocating to another country in the future. At the same time, the procedure for applying the new provisions to participants in the special tax regime requires further legal clarification.
However, the proposed mechanism is not a general tax on departure from Italy and does not provide for the automatic levying of 26% on the value of residential real estate or an individual’s total assets.
The bill must be reviewed and approved by the Italian Parliament by the end of 2026. During the legislative process, the tax rate, the conditions for its application, and the procedure for granting deferrals may be amended.
Italy remains one of Europe’s largest real estate markets and a popular destination for international investors, particularly those considering purchasing a home in conjunction with transferring their tax residency. The proposed changes may become an additional factor in choosing a country of residence and in long-term investment planning.
Sources: Italy’s 2027–2029 Budget Bill, Article 17, approved by the government on October 28, 2026; President of Italy, official approval of the bill’s submission on October 30, 2026; Investment Migration Insider, October 31, 2026.
