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J&L Consulting Newsletter December 2025

  • Cabinet Lifts Capacity Limit for Energy Generation Projects During Wartime
  • New Government Mechanism Introduced for Compensating War-Related Business Losses
  • Tax Service Outlines Requirements for Inclusion in High-Compliance Taxpayer List

 

 

Cabinet Lifts Capacity Limit for Energy Generation Projects During Wartime

The Cabinet of Ministers of Ukraine has adopted Resolution No. 1542 on November 28, 2025, amending its earlier Resolution No. 1320 of December 7, 2023. The updated regulation concerns the construction, restoration, reconstruction, placement, or major repair of various energy infrastructure facilities – including gas-piston and gas-turbine units, cogeneration plants, modular boiler houses, diesel, gasoline, and gas generators, as well as energy storage installations and segments of the gas and electricity transmission systems.

The key change introduced by Resolution No. 1542 is the removal of the minimum capacity threshold of 1 MW for energy installations covered under the previous rules. This means that even small-scale units can now be built or restored under the simplified procedures applicable during the period of martial law.

The decision aims to expand the range of projects eligible for fast-track implementation, supporting greater energy resilience and decentralization amid ongoing wartime challenges. By allowing smaller facilities to be included, the government seeks to accelerate the deployment of local energy sources and backup systems critical for stability and recovery.

Resolution No. 1542 entered into force on November 29, 2025.

 

New Government Mechanism Introduced for Compensating War-Related Business Losses

The Cabinet of Ministers has adopted Resolution No. 1541 (November 28, 2025), which establishes a formal procedure for partial compensation of property damaged or destroyed as a result of Russia’s armed aggression, as well as partial reimbursement of insurance premiums under war-risk insurance contracts. The resolution entered into force on November 29, 2025 and will apply starting January 1, 2026.

The compensation mechanism covers business assets located in high-risk territories that have suffered damage or destruction due to war-related events defined in the procedure. This includes a broad range of incidents stemming directly from military aggression.

A separate component of the procedure governs reimbursement of insurance premiums for assets insured against war risks. This applies to property located anywhere in Ukraine except for territories under temporary Russian occupation or those officially listed as active combat zones without an established end date of occupation.

The framework explicitly excludes compensation both for losses and insurance premiums if, at the moment the resolution took effect, the business property was located on territory that remained under temporary occupation or classified as a combat zone.

Financing for all forms of compensation will come exclusively from the state budget, offering businesses a partial financial safeguard as they navigate the consequences of wartime damage and ongoing security risks.

 

Tax Service Outlines Requirements for Inclusion in High-Compliance Taxpayer List

The State Tax Service of Ukraine (STS) has issued guidance explaining the criteria for inclusion in its quarterly List of Taxpayers with a High Level of Voluntary Tax Compliance. The list, published on the STS web portal, highlights businesses that demonstrate consistent discipline, transparency, and responsible tax behavior.

The criteria apply across several taxpayer categories, including:

  • legal entities under the general taxation system;
  • Diia.City residents;
  • legal entities under the simplified tax system (Groups III and IV);
  • individual entrepreneurs under the general system;
  • individual entrepreneurs in Group III of the simplified system.

The STS notes a set of common mandatory requirements that all categories must meet:

  • timely submission of all tax reports;
  • no VAT risk-payer status;
  • no outstanding tax or social contribution debt;
  • no breaches of export–import settlement deadlines within the past 12 months;
  • no sanctions applied to the taxpayer, its founders, or ultimate beneficial owners;
  • no bankruptcy or liquidation procedures underway;
  • no citizenship ties with the aggressor state among taxpayers, founders, or beneficiaries;
  • no changes to the primary economic activity code over the past 12 months;
  • full compliance with category-specific criteria;
  • at least one year of registration with the STS.

The guidance seeks to promote fairness and predictability in tax administration while encouraging responsible behavior among Ukrainian businesses of all sizes.

 

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