UOGA WARNS: ABOLITION OF ADVANCE PAYMENTS COULD UNDERMINE THE ACHIEVEMENTS OF FUEL MARKET DE-SHADOWING
Kyiv, 20 February — The Ukrainian OIl&Gas Assosiation (UOGA) has expressed concern regarding Draft Law No. 15012 dated 6 February 2026, which provides for the abolition of advance corporate income tax payments for the retail fuel trade.
The Association cautions that such an initiative may negate the results of many years of work aimed at de-shadowing the fuel market and weaken tax discipline within the sector. UOGA has already submitted an official letter to the Ministry of Energy of Ukraine and to the Chair of the Verkhovna Rada Committee on Finance, Taxation and Customs Policy, urging them not to support the proposed amendments.
UOGA recalls that advance payments were introduced by Law No. 4015-IX in October 2024 as an instrument to combat tax evasion in the fuel market.
UOGA President Yaroslav Starovoitenko explains:
“In 2024, the state drew attention to a revealing feature of Ukraine’s retail fuel market: the overwhelming majority of filling stations declared a lack of profitability. In practice, fuel had been sold for years, yet financial reporting recorded a zero financial result and, accordingly, no corporate income tax was paid.
A business entity operates with the objective of generating profit, and if, month after month and year after year, such activity remains unprofitable while the business continues to operate, this quite naturally raises questions.
At the same time, of the UAH 15.7 billion in operational taxes paid by fuel companies in 2024, nearly 20% accounted specifically for corporate income tax. In other words, one part of the market pays taxes, while another systematically reports losses.”
“According to industry experts, the average monthly corporate income tax paid by filling station networks that, until 2025, had demonstrated almost no profitability increased more than sevenfold.
In the first nine months of 2024, the total corporate income tax paid by all filling station networks in Ukraine amounted to UAH 1.57 billion, whereas in the corresponding period of 2025 it reached UAH 2.1 billion. Thus, state budget revenues increased by more than 30%.
In terms of defence needs, this is equivalent to financing more than 20,000 FPV drones, underscoring the significance of these revenues for the country amid a full-scale war,” Yaroslav Starovoitenko noted.
This confirms that the mechanism of advance payments has become an effective instrument for strengthening tax discipline and providing additional revenues to the state budget.
UOGA warns that abolishing this mechanism during martial law may:
- weaken tax discipline;
- create unequal competitive conditions;
- reduce state budget revenues.
UOGA calls upon the Ministry of Energy of Ukraine, Members of Parliament and the Government to take into account the tangible results of fuel market de-shadowing and to refrain from supporting Draft Law No. 15012 in its current version. The Association reaffirms its readiness for continued professional dialogue with state authorities on improving tax policy in the fuel sector.
