Experts of the NGO “Ukrainian Modern Digital Science” (UMDS) —
Tetiana Dmytrenko, Oleksii Feshchenko, and Viacheslav Cherkashyn —
submitted official proposals for the second reading of the Draft Law No. 10225-d dated April 24, 2025, “On Amendments to the Tax Code of Ukraine and Certain Other Legislative Acts Regarding the Regulation of Virtual Assets in Ukraine”, registered by the Verkhovna Rada Committee on Finance, Tax, and Customs Policy.
The experts emphasized the need for clear separation between tax and regulatory provisions, as well as for a dedicated legislative framework for virtual assets.
Key comments include:
- inconsistency of the draft with the Tax Code’s provisions that amendments should be introduced only by separate laws;
- potential tax risks for Diia.City residents engaged in virtual asset operations;
- lack of clear regulation for derivative financial instruments linked to virtual assets;
- the need for balanced implementation of the FATF Travel Rule to avoid excessive compliance burdens;
- and concerns over discriminatory provisions that would deny taxpayers the right to account for expenses related to operations with virtual assets if the issuer loses authorization after the transaction.
UMDS experts underlined that Ukraine’s new legislation should support innovation and technological development while ensuring financial integrity and consumer protection.
The organization proposed editorial amendments and regulatory recommendations aligned with international best practices and FATF, EU, and OECD standards.