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\nVadym Lozytskyi<\/b>,<\/strong>
\nAuditor at LLC AF “AUDIT-INVEST”<\/span><\/div>\n<\/div>\n
Large Taxpayers under the Tax Code of Ukraine and Large Enterprises under the Law of Ukraine on Accounting and Financial Reporting\u2014who are they, and what is the difference? According to Ukrainian legislation as of 2026, the criteria for determining “large” business entities differ depending on the purpose: for taxation or for financial reporting. Let’s break it down.<\/p>\n
\u00a0\u0417\u043c\u0456\u0441\u0442 \u0441\u0442\u0430\u0442\u0442\u0456<\/strong><\/h3>\n\n- What is a Large Taxpayer (LTP)?<\/a><\/li>\n
- What is a Large Enterprise?<\/a><\/li>\n
- Main Differences (Table)<\/a><\/li>\n
- Who is Obliged to Apply IFRS?<\/a><\/li>\n
- Mandatory Audit of Financial Statements<\/a><\/li>\n<\/ol>\n<\/div>\n
1. Large Taxpayer (LTP)<\/h2>\n
Defined by the Tax Code of Ukraine (sub-paragraph 14.1.24), a “Large Taxpayer” is a legal entity or a permanent establishment of a non-resident in Ukraine that meets specific financial thresholds.<\/p>\n
\nThe LTP status is assigned to an entity that satisfies at least one of the following criteria over the last four consecutive tax quarters:<\/p>\n
\n- \n
Income Volume: Total income from all types of activity exceeds the equivalent of 50 million euros, calculated at the weighted average official exchange rate of the National Bank of Ukraine (NBU) for that period.<\/p>\n<\/li>\n
- \n
Tax Payments: The total amount of taxes, fees, and payments made to the State Budget of Ukraine (excluding customs duties) exceeds the equivalent of 1.5 million euros, calculated at the weighted average official NBU exchange rate for that period.<\/p>\n<\/li>\n<\/ul>\n<\/div>\n
It is important to note that this status does not arise automatically. The State Tax Service (STS) compiles and approves the list of Large Taxpayers annually. An entity is officially considered an LTP only from the date it is included in this list, rather than immediately upon hitting the financial marks.<\/p>\n
Such companies are serviced by a specialized body: the Interregional Department of the STS for Large Taxpayers. The full list for the current year can be found in the official Register of Large Taxpayers.<\/p>\n
\n- \u00a0<\/span><\/li>\n<\/ul>\n
2. Large Enterprise<\/h2>\n
The definition of a “Large Enterprise” is established by the Law of Ukraine “On Accounting and Financial Reporting in Ukraine” (Article 2). This category includes business entities that do not fall under the “small” or “medium” categories and meet at least two of the three following criteria (based on the annual financial statements for the year preceding the reporting year):<\/p>\n
\n- \u2192<\/span>Total Assets: Over 20 million euros.<\/li>\n
- \u2192<\/span>Net Sales Revenue: Over 40 million euros.<\/li>\n
- \u2192<\/span>Average Number of Employees: Over 250 people.<\/li>\n<\/ul>\n
The “Two-Year Rule” for Status Transition<\/p>\n
A key feature of this classification is the stability of the status. A category is determined based on indicators for two consecutive years.<\/p>\n
\n- \n
Acquiring the status: If an enterprise meets at least two of the “large” criteria for two years in a row, it officially becomes a “Large Enterprise” starting from the third year.<\/p>\n<\/li>\n
- \n
Losing the status: To transition to a lower category (e.g., medium), the enterprise must fail to meet the “large” criteria for two years in a row.<\/p>\n<\/li>\n<\/ul>\n
Example: If your company met the criteria in 2024 and 2025, it is considered a “Large Enterprise” for the 2026 reporting period.<\/p>\n
For the purpose of currency conversion into UAH, the legislation requires using the average annual official exchange rate of the NBU for the relevant period.<\/p>\n
3. Key Differences<\/h2>\n
1. Large Taxpayer (LTP)<\/h2>\n
Defined by the Tax Code of Ukraine (sub-paragraph 14.1.24), a “Large Taxpayer” is a legal entity or a permanent establishment of a non-resident in Ukraine that meets specific financial thresholds.<\/p>\n
The LTP status is assigned to an entity that satisfies at least one of the following criteria over the last four consecutive tax quarters:<\/p>\n
- \n
- \n
Income Volume: Total income from all types of activity exceeds the equivalent of 50 million euros, calculated at the weighted average official exchange rate of the National Bank of Ukraine (NBU) for that period.<\/p>\n<\/li>\n
- \n
Tax Payments: The total amount of taxes, fees, and payments made to the State Budget of Ukraine (excluding customs duties) exceeds the equivalent of 1.5 million euros, calculated at the weighted average official NBU exchange rate for that period.<\/p>\n<\/li>\n<\/ul>\n<\/div>\n
It is important to note that this status does not arise automatically. The State Tax Service (STS) compiles and approves the list of Large Taxpayers annually. An entity is officially considered an LTP only from the date it is included in this list, rather than immediately upon hitting the financial marks.<\/p>\n
Such companies are serviced by a specialized body: the Interregional Department of the STS for Large Taxpayers. The full list for the current year can be found in the official Register of Large Taxpayers.<\/p>\n
- \n
- \u00a0<\/span><\/li>\n<\/ul>\n
2. Large Enterprise<\/h2>\n
The definition of a “Large Enterprise” is established by the Law of Ukraine “On Accounting and Financial Reporting in Ukraine” (Article 2). This category includes business entities that do not fall under the “small” or “medium” categories and meet at least two of the three following criteria (based on the annual financial statements for the year preceding the reporting year):<\/p>\n
- \n
- \u2192<\/span>Total Assets: Over 20 million euros.<\/li>\n
- \u2192<\/span>Net Sales Revenue: Over 40 million euros.<\/li>\n
- \u2192<\/span>Average Number of Employees: Over 250 people.<\/li>\n<\/ul>\n
The “Two-Year Rule” for Status Transition<\/p>\n
A key feature of this classification is the stability of the status. A category is determined based on indicators for two consecutive years.<\/p>\n
- \n
- \n
Acquiring the status: If an enterprise meets at least two of the “large” criteria for two years in a row, it officially becomes a “Large Enterprise” starting from the third year.<\/p>\n<\/li>\n
- \n
Losing the status: To transition to a lower category (e.g., medium), the enterprise must fail to meet the “large” criteria for two years in a row.<\/p>\n<\/li>\n<\/ul>\n
Example: If your company met the criteria in 2024 and 2025, it is considered a “Large Enterprise” for the 2026 reporting period.<\/p>\n
For the purpose of currency conversion into UAH, the legislation requires using the average annual official exchange rate of the NBU for the relevant period.<\/p>\n
3. Key Differences<\/h2>\n
- \u2192<\/span>Net Sales Revenue: Over 40 million euros.<\/li>\n
- \u2192<\/span>Total Assets: Over 20 million euros.<\/li>\n
- \u00a0<\/span><\/li>\n<\/ul>\n
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