Client Alert for Foreign Marketplaces and Cross-Border E-Commerce Operators: Ukraine May Introduce Platform-Level VAT on All International Parcels – Legislative Process Ongoing

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Headline development

On 6 May 2026, the Ukrainian Parliament's Committee on Finance, Tax and Customs Policy upheld draft laws No. 15112-D and No. 12360, which, if passed, would make foreign online marketplaces (Amazon, eBay, AliExpress, Temu, Shein and comparable platforms) directly liable for Ukrainian VAT on every B2C sale delivered into Ukraine.

The proposed effective date of the laws is 1 January 2027. A transition period is also provided for: during the first year of the system’s implementation, no administrative penalties will be imposed for unintentional errors in VAT payments. A committee recommendation is a procedural step only; the draft laws still require adoption by Parliament and presidential signature before becoming law, and material amendments remain possible. If enacted in their current form, the package would abolish the EUR 150 VAT-free threshold for marketplace purchases and transpose an EU-style deemed-supplier / IOSS model into Ukrainian law.

Core obligations that would apply to marketplaces if the law is passed

• Deemed supplier status: the foreign platform (not the underlying seller and not the buyer at customs) would become the VAT payer for goods sold to Ukrainian consumers.
• 20% VAT from the first euro: VAT would have to be charged, collected and displayed at checkout on every consignment, with no de minimis for marketplace sales.
• Remittance to the Ukrainian budget: platforms would be required to register, file returns and remit VAT collected from Ukrainian buyers.
• Automatic data exchange: platforms would share transactional data with Ukrainian tax and customs authorities, mirroring EU IOSS information flows.
• Customs duty unchanged above EUR 150: import duty would continue to apply to consignments exceeding EUR 150, in addition to the new platform-level VAT.

Impact map by business type (conditional on adoption)

Consumer-facing changes

• 20% VAT on every marketplace order delivered to Ukraine, shown at checkout rather than collected at customs.
• C2C (private person to private person) parcels would remain VAT-free up to EUR 45, subject to non-commercial use and gift character; this exemption would not apply to marketplace sales.
• Excise goods, perfume above the allowance, coffee over 500 g and tea over 100 g would be taxed in full even within C2C flows, and fully under the marketplace regime.

Policy rationale

The reform is driven by Finance Committee Chair Mr. Danylo Hetmantsev and supported by major Ukrainian business associations, which argue that untaxed low-value imports from Shein, Temu and similar platforms cost the State Budget billions of UAH annually and distort competition with domestic retailers. The model is explicitly aligned with EU VAT rules for distance sales of imported goods (IOSS), which would make Ukraine's regime familiar to globally operating platforms already compliant in the EU.

Legislative risk and points of contention

Several MPs, logistics executives and economists oppose the package, warning that a zero-euro threshold would raise consumer prices, depress cross-border e-commerce volumes and disproportionately harm Ukrainian logistics operators reliant on inbound parcel flows. These concerns create a realistic possibility that the draft laws may be amended, delayed or rejected; amendments on the C2C EUR 45 exemption, excise carve-outs, the deemed-supplier perimeter and the effective date are all plausible before a second reading.

Indicative legislative timeline (subject to change)

Recommended action items

• Marketplaces: begin contingency planning for Ukrainian VAT registration and deemed-supplier liability mapping, while calibrating investment to the still-uncertain probability of enactment.
• Platform tax and legal teams: draft, but do not yet deploy, updates to seller terms, checkout tax logic and data-exchange interfaces; monitor amendments in the parliamentary process.
• Logistics, postal and express operators: scope the required changes to customs declaration systems and commercial arrangements with marketplaces, ready to activate if the law passes.
• Payment and checkout vendors: pre-configure a Ukrainian 20% VAT option as an optional, switch-ready module.
• Ukrainian retailers and brand owners: prepare pricing and assortment scenarios for both adoption and non-adoption outcomes.

Our Tax and Customs practice is available to advise on scenario planning, Ukrainian VAT registration readiness, deemed-supplier structuring, seller-agreement design, customs-clearance workflows and real-time parliamentary monitoring.