Ukraine exempts imported energy-generating equipment from VAT and duty until 1 January 2026

What changed in detail

Law of Ukraine No. 3853-IX of 16 July 2024 amends subsection 2 of Section XX of the Tax Code. Its companion, Law No. 3854-IX of the same date, amends the Customs Code. Law 3853-IX was published in Holos Ukrainy No. 89 on 26 July 2024 and, under its final provisions, entered into force the day after publication, 27 July 2024.

Law 3853-IX adds two points to the Tax Code’s transitional provisions:

• Point 87¹: temporarily, for the period of martial law but no later than 1 January 2026, imports of the goods listed in point 9-36 of Section XXI of the Customs Code are exempt from VAT. Goods originating in, or imported from, the occupying (aggressor) state or the temporarily occupied territories are excluded.
• Point 88¹: on the same terms, imports of goods on a Cabinet of Ministers list are exempt where they are made under agreements financed by the Energy Community Secretariat, as confirmed by the energy ministry.

Law 3854-IX adds point 9-36 to the Customs Code, which lists the goods and exempts them from import duty. The list covers electric generators above 750 kVA, generating sets, gas, steam and hydraulic turbines, inverters, battery storage of 300 W or more, solar modules, switchgear and wind-generator parts. A complete wind-powered generating set (HS 8502 31) was not on it.

The bills were introduced on demining machines and drones; the energy points were added at second reading.

What it means

The 1 January 2026 end date never bit. Laws 4698-IX and 4710-IX of December 2025 moved the end date of points 87¹, 88¹ and the customs list to 1 January 2029, and added complete wind-powered generating sets to the list; see the 2025 extension. The exemption also ends early if martial law ends before then.

The relief is defined by HS code, not by project type. An importer needs its goods to sit under a listed code, and a complete wind turbine imported in 2024 or 2025 did not qualify.