Offshore jurisdictions Ukraine: “black” list of offshore jurisdictions of the Cabinet of Ministers of Ukraine 2026

An offshore company is useful when the jurisdiction is selected for a specific transaction, business bank account and way of receiving profit. International and national lists provide an additional reference point for comparing countries by tax regime, information exchange and banking practice. A practical plan is to compare several jurisdictions and choose the structure that best matches the commercial task.

Blacklist — good or bad? Nothing changed in 2026.

The fact that a country is on the blacklist of the Cabinet of Ministers of Ukraine or any other country does not in itself mean that a company from that country should not be used or that using it creates increased business risk. Different “blacklists” are regularly prepared and updated in the European Union and the USA. Individual jurisdictions may also maintain additional lists of undesirable countries or countries with a high money-laundering risk, including Latvia and other Baltic states, Cyprus and EU countries.

If this list is considered from the point of view of reliability and the limited disclosure of information by official sources, all countries on it could be given a “Recommended” rating in the “Best choice” category under the new Tax Code as a base for holding funds, holding structures and confidential ownership of assets. The presence or absence of a country on this list only means that the level of cooperation by that country on tax and legal matters with the official authorities of another country is considered insufficient.

If an agreement is not reached for one reason or another, another country may place a jurisdiction on a list of higher-risk countries, on a list of countries whose bank transactions require special attention, or may require details about the actual owners and recipients of funds, central-bank approval of such transactions, or may classify transactions with such countries or payments to banks in such countries as “controlled transactions”. The consequences may differ depending on the list in which the jurisdiction is included.

Looking at the reverse situation, there are countries such as the United Kingdom, LTD companythat have never appeared on such lists and are unlikely to do so in the foreseeable future. These countries should be considered when choosing a jurisdiction for a new business bank account for international business.

Countries are generally placed on a “blacklist” when they do not provide confidential information about business owners and have statutory tax benefits that exempt all company income from tax, do not require accounting and financial reporting, or exchange insufficient information about beneficial owners or other information. In practice, inclusion on the “blacklist” used to mean that if a Ukrainian company entered into a transaction with an offshore company to purchase or import goods or services, only 85% of the contract amount could be treated as gross expenses, or the transaction could fall under controlled-transaction or transfer-pricing rules. In this way the state increased the tax base for transactions with offshore companies and certain other countries that either offered tax benefits or did not provide sufficient information on request for various reasons.

If an offshore company from the “blacklist” acts as the customer, that is, a Ukrainian company enters into a transaction with the offshore company to sell or export goods or services, there is no difference in profit-tax payment. However, the bank receiving the money may still request more documents than for other countries under anti-money-laundering and counter-terrorist-financing rules. This should also be kept in mind. Similar laws have now been adopted in practically all countries and are applied to one degree or another by all banks.

Thus, the presence of a company or bank on a “blacklist” or “controlled” list can, on the one hand, indicate that taxes and reporting in these countries are absent or lower than in Ukraine and that this is established by local law, or that other more favourable conditions for doing business exist in tax legislation, such as lower tax rates, exemption of some or all foreign-trade transactions from tax, or other tax benefits.

The European Union also has its own “offshore blacklist”. As of 17 February 2026, the EU list includes American Samoa, Anguilla, Guam, Palau, Panama, Eastern Europe, Turks and Caicos Islands, United States Virgin Islands, Vanuatu and Vietnam. The list is reviewed regularly and is used separately from Ukrainian lists.

The list initially included 17 jurisdictions, but it is subject to regular review. Countries with legal deficiencies are added if they do not amend their rules within the specified time.

Each jurisdiction should be considered individually and the decision should depend on the specific circumstances. In any case, if your Ukrainian company has payments connected with these jurisdictions, you should be prepared to provide additional information about your foreign partners in those countries, obtaining as much information as possible about the company and controlling persons. Your servicing bank will most likely request this information in documentary form.