State Tax Service Knows about Ukrainians’ Accounts in Switzerland, Germany and Austria: What Next?

During the war, tens of thousands of Ukrainians moved their financial assets abroad, while remaining tax residents of Ukraine or having multiple tax residences. Financial institutions and tax authorities of Ukraine and the countries where financial assets are located exchange information about them via CRS (automatic exchange of financial and tax information). Therefore, failure to declare financial assets threatens not only with fines in Ukraine, but also with the conditional status of a “disloyal client” in foreign financial institutions. Here’s what you need to know to avoid these consequences as explained by Senior Partner of K.A.C. Group Volodymyr Harkusha.

Results of 2025 and Plans for CRS 3.0 in 2026

In the summer of 2025, the OECD presented a report on the current status of the implementation of standards for the automatic exchange of financial information: 172 jurisdictions have committed to implementing various formats for the exchange of tax information, and 112 countries are already actively exchanging data according to the CRS standard, with another 15 joining the exchange in 2026.

At the beginning of 2025, tax administrations around the world had exchanged data on 171 million financial accounts with a total asset volume of over 13 trillion euros, which provided billions in revenue to budgets. This year, 69 states, including Ukraine, have committed to implementing the Crypto-Asset Reporting Framework (CARF) by 2026−2028.

The OECD updates for 2025 focus on three main points:

1. Crypto Asset Reporting Framework (CARF) — XML scheme and detailing of reporting and feedback on data submitted by financial institutions. This practically de-anonymizes the owner of the crypto asset.

2. Expansion of the Reporting Standard (CRS). It now covers electronic money products (and their derivatives — derivatives or other investment instruments) and central bank digital currencies (CBDCs).

3. Updated XML CRS Status Reporting Scheme — version 3.0 (yes, already 3.0!). These are purely technical aspects that align the CRS and CARF updates, ensuring their long-term compatibility.

These updates have been worked out and agreed upon over the course of a year and will be launched from January 1, 2026.

CRS 2025 in Ukraine: What the Tax Authorities Already Know

In 2025, the State Tax Service of Ukraine launched the development of the IT system “Exchange of Information with Foreign Competent Authorities”, which should ensure transparency of processes, control of the terms and quality of exchange, as well as increase the efficiency of the Tax Service in combating international tax evasion schemes.

As evidenced by the results of reporting on CFCs (controlled foreign companies) for 2022−2023 published in January 2025, Ukrainian residents submitted 39,058 reports on 23,689 CFCs in 119 countries. Ukraine will automatically exchange information with all these countries within the framework of the CRS. Information on CFCs of Ukrainian residents registered in the United States, which are not a party to the CRS Agreement, will be provided through the American information exchange system, FATCA.

The second automatic exchange of financial and tax information took place in October 2025. This time, the tax office received data not only on new accounts, but also on accounts opened before July 1, 2023. This time, 71 foreign jurisdictions shared information with Ukraine, which is 21 countries more than in 2024. In particular, the UAE, Austria, Germany and Switzerland, which previously refrained from exchanging information with Ukraine, joined the automatic exchange. Now their position has changed: Ukraine will receive the first data for 2024 from Austria and the United Arab Emirates in 2025, and from Switzerland and Germany — in 2026 for 2025. As a result, all accounts of Ukrainian residents opened in Swiss, German, UAE and Austrian financial institutions will now be fully reflected in the databases of the State Tax Service of Ukraine.

We will see the practical consequences of the automatic exchange of information for 2025 later. It will take time for the State Tax Service of Ukraine to compare data on assets and income indicated in tax declarations and CFC reports with information received within the CRS. After identifying discrepancies, the State Tax Service of Ukraine will begin sending requests for documents and explanations regarding the identified discrepancies.

If the Tax Service does not receive a response, receives it late, or considers the information insufficient, it will launch tax audits. In case of confirmation of non-declaration and non-payment of taxes on income on foreign accounts, the Tax Service will additionally charge 18% personal income tax and 5% military levy, as well as penalties and interest. Then, most likely, in March 2026, the STS will proudly report on millions in budget revenues from taxes and fines, and media will be oversaturated with various materials on the topic of Article 212 of the Criminal Code of Ukraine.

CRS-2026: More Information for the Tax Administration

From January 1, 2026, an updated version of the financial information exchange standard (CRS 3.0) will be launched, which significantly expands the list of information subject to automatic exchange, namely: electronic money in electronic wallets and payment systems, central bank digital currencies (CBDCs), crypto derivatives and financial instruments derived from them.

The list of accountable financial institutions (in addition to standard ones — banks, payment systems, insurance companies, etc.) includes institutions that store electronic money or CBDCs, as they will now be classified as depository institutions.

In principle, the innovations of 2026 in the field of automatic exchange of information will mainly concern crypto-assets. 69 countries, including Ukraine, have committed to introducing the Crypto-Asset Reporting Framework (CARF) by 2027−2028. In Europe, this standard will come into effect from January 1, 2026 under the DAC8 Directive.

This means that by 2028 at the latest, information on all transactions with virtual assets will be subject to the same automatic exchange as is currently the case with bank account information. Key changes to the CARF standard in 2026 are:

◉ decentralized digital platforms (even non-custodial DeFi protocols) will be subject to reporting obligations if they actually control customer transactions or perform intermediary functions,

◉ liquid staking — transferring assets for staking and receiving rewards in the form of tokens is equated with crypto assets and must be reported,

◉ identification mechanisms are being introduced: ways to identify responsible persons even in decentralized protocols (through front-end operators or key developers).

The updated CRS 3.0 standard from January 1, 2026 significantly deepens the identification of a person subject to automatic exchange of information. Financial institutions can now directly verify information on the tax residency of a client through state verification services.

For instance, if a tax certificate from Greece is submitted to a bank, the bank can directly contact the Greek tax authorities and request appropriate confirmation. The bank may conclude that the person is a resident not only of the country whose passport he or she provided, but also of the country of actual residence. For persons with special preferential regimes (citizenship or residency by investment), an enhanced verification procedure will be applied.

Financial institutions will be required to clearly distinguish between the account owner and the account controller, i.e. nominal owners, fiduciaries and beneficial owners must be identified separately. The bank must determine the true owner who receives economic benefits from the account, even if he or she does not formally control it. By the way, in Ukraine, an account holder who intentionally provides false information and because of this their account was not determined as accountable falls under Article 118-1 of the Tax Code of Ukraine, the fine being 100 times the minimum wage.

During 2026, the OECD plans to finalize the rules and standards for the exchange of information on real estate and income from them under MCAA (IPI MCAA). Real estate objects, land plots owned by individuals and legal entities will fall under the information exchange. Sources of information are state land cadastres and registers, tax and municipal databases.

What Are the Next Steps?

International asset search systems and the practical use of these searches are constantly being improved. It is no longer that important whether the system sees your money as such, but when, how and with what consequences. Danylo Hetmantsev, Head of the Verkhovna Rada Committee on Finance, Tax and Customs Policy, has already clarified that “the CRS data obtained is not automatic evidence in tax cases”. However, practice proves the opposite: the data obtained on foreign assets serve as a catalyst for a surge in prosecutions under Article 212 of the Criminal Code of Ukraine.

Based on the fact that the information control and exchange system tracks you even before you make a mistake, it makes no sense to build your own financial system with tolerances bordering on legal fouls. Your scheme should not differ from the usual one. For example, the fact that a Kyiv resident doing business in Poland declares themselves to a bank as a tax resident of Greece goes beyond the usual situation and will cause the appropriate consequences.

The alternative is to build a business scheme, and even your own life, in countries that do not yet cooperate with the OECD and do not implement CRS and CARF. The question is, for how long will this option be viable?

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