Ukraine and CRS: New jurisdictions for automatic exchange of financial information

Ukraine Joined the CRS Framework

Ukraine joined the international standard for automatic exchange of financial information – Common Reporting Standard (“CRS”) in August 2022, by signing the Multilateral Agreement of the Competent Authorities of the Organization for Economic Co-operation and Development (OECD). On April 28, 2023, the Law of Ukraine “On Amendments to the Tax Code of Ukraine and Other Legislative Acts of Ukraine Regarding the Implementation of the International Standard for Automatic Exchange of Financial Account Information” entered into force.

First Exchange of Information

The first exchange of information for year 2023 took place in 2024. Based on the results of this exchange, the State Tax Service of Ukraine reported on the data received from about 50 foreign jurisdictions and the transfer of information to 51 jurisdictions.

Expanding the exchange: Austria and Switzerland

In 2024, several jurisdictions, in particular Austria and Switzerland, refrained from exchanging information with Ukraine. However, their position has now changed, and Ukraine will receive the first data for year 2024 from Austria in 2025, and from Switzerland in 2026 for year 2025.

• Austria recently added Ukraine to the list of countries with which automatic exchange of financial information is carried out. The corresponding resolution of the Austrian Federal Ministry of Finance entered into force on May 1, 2025.

This means that for the reporting year 2024, Austrian banks and other financial institutions are obliged to transfer to the Ukrainian tax authorities data on accounts whose beneficial owners are Ukrainian tax residents.

• Switzerland has also confirmed the launch of the CRS with Ukraine from January 1, 2025. This means that Swiss banks have already started collecting information for year 2025, and the first exchange will take place in 2026. Therefore, data on all active accounts of Ukrainian residents in Switzerland for year 2025 will be automatically transferred to the tax authorities of Ukraine.

Given that Switzerland has traditionally been considered one of the most “confidential” jurisdictions for capital allocation, the launch of the CRS between Ukraine and Switzerland is a fundamental change: from now on, Ukrainian accounts in this country are subject to the same transparent reporting as in other exchange participants.

Scope and content of the transferred information

Within the framework of the CRS standard, not only the fact of the existence of an account is transferred, but also a wide range of financial and identification data. In particular, banks report:

• name, address, tax identification number (TIN), date and place of birth of the account holder;
• account number and details of the financial institution;
• the balance or value of the account at the end of the reporting year (or on the date of its closure), as well as
• income related to the account: interest, dividends, other financial income and proceeds from the sale of assets.

Conclusion

As a result, all accounts of Ukrainian residents opened in Swiss and Austrian financial institutions will now be fully reflected in the databases of the State Tax Service of Ukraine.

We emphasise that the transfer of data on financial accounts of Ukrainian residents from foreign jurisdictions is mandatory. We will closely monitor this information and inform you of all updates.

For additional information on the details of the exchange procedure under the CRS standard, please contact partner of the Tax practice Anton Zaderyholova.