Wartime VAT Exemption for Ground Robotic Systems and Record VAT Refunds in the Odesa Region

VAT exemption for unmanned ground systems. Under Law No. 4894-IX (adopted 28 May, in force 31 May 2026), Ukraine temporarily exempts from VAT the domestic supply of ground robotic complexes/unmanned ground systems for defence needs. It applies only to goods in UKT ZED groups 84, 85, 87, 90 and 93 supplied under state defence-procurement contracts, or where the end recipient is the Ministry of Defence, Armed Forces, law-enforcement bodies or defence contractors. [tax.gov.ua], [lexcovery.com], [vatupdate.com]
Why it matters. The relief restores a benefit lost on 1 January 2026 when a broader electric-vehicle exemption expired, which had pushed the cost of these systems up by the standard 20% VAT and nearly halted supply. Removing that burden lowers acquisition costs and speeds up delivery of robotic platforms to frontline units during martial law. [zn.ua], [thedefensenews.com]
Strong refund performance in Odesa. Ukraine’s State Tax Service reports that in H1 2026, 182 businesses in the Odesa region claimed over UAH 1.7 billion in VAT refunds, of which UAH 1.5 billion was actually repaid to 165 companies. At the same time, refunds of UAH 43.7 million to 36 companies were blocked following control checks — presented by the authorities as evidence of transparent, timely VAT administration. [od.tax.gov.ua]

1. VAT exemption for ground robotic complexes (Law No. 4894-IX)

On 28 May 2026 the Verkhovna Rada adopted Bill No. 15259 (294 votes in favour), signed by the President on 29 May and effective from 31 May 2026 as Law No. 4894-IX. It inserts a new paragraph 99¹ into Subsection 2 of Section XX (“Transitional Provisions”) of the Tax Code, temporarily exempting from VAT — for the duration of martial law — the supply within Ukraine’s customs territory of ground unmanned/robotic systems. [rada.gov.ua], [itd.rada.gov.ua], [radnuk.com.ua]

The exemption is conditional and narrow. Two requirements must be met simultaneously:

Classification: the goods must fall under UKT ZED commodity groups 84, 85, 87, 90 or 93 (and must genuinely be unmanned ground systems, not just any goods in those groups); and
Targeted purpose: the supply is made under a state defence-procurement contract, and/or the end recipient (per an end-user certificate or contract terms) is the Ministry of Defence, Armed Forces, law-enforcement agencies, other/volunteer military formations, national-security actors, or contractors/subcontractors on state defence contracts. [lexcovery.com], [i.factor.ua]

If either condition fails (no defence contract or an ineligible end user), the exemption does not apply. The policy driver is explicit: after the electric-vehicle VAT relief lapsed on 1 January 2026, ground robotic systems lost coverage and their procurement price rose by 20%, sharply reducing supply. According to Defence Procurement Agency (DOT) director Arsen Zhumadilov, the fix removes that extra burden and speeds contracting-to-delivery. As of May 2026, Ukraine’s forces had received over 1,000 such complexes worth more than UAH 487 billion via the DOT-Chain Defence marketplace. [i.factor.ua] [zn.ua], [finway.com.ua]

Note that the State Tax Service has already issued individual tax consultations (e.g. IPK No. 566/IPK of 27.01.2026 and IPK No. 5877/IPK of 03.11.2025) clarifying classification questions — for example for mine-laying platforms under UKT ZED 8704 60 00 00 — underlining that correct customs classification and proof of defence end-use are decisive for the relief. [zvit.vchasno.ua], [zvit.vchasno.ua]

Sources / external links:

State Tax Service (English): Tax benefit: ground-based robotic complexes exempted from VAT
State Tax Service (Ukrainian): Податкова пільга: наземні роботизовані комплекси…
Verkhovna Rada: Звільнення від ПДВ операцій із постачання наземних роботизованих комплексів — Закон ухвалено
Bill card No. 15259 / Law 4894-IX: itd.rada.gov.ua
VATupdate: Ukraine Exempts Ground Robotic Systems from VAT for Defense Supplies
Lexcovery (English legal analysis): On Amending the Tax Code… supply of ground robotic complexes
ZN.ua: Рада звільнила від ПДВ поставки наземних безпілотних комплексів

2. Record VAT refunds in the Odesa region (H1 2026)

The Main Directorate of the State Tax Service in the Odesa region reported that, for January–June 2026, 182 taxpayers claimed more than UAH 1.7 billion in budget VAT refunds. Of that, UAH 1.5 billion was actually refunded in cash to 165 enterprises (including carried-over amounts from prior periods). Head of the regional directorate, Yurii Hurskyi, framed VAT refunds as both a fulfilment of the state’s obligations to compliant taxpayers and a key element of a favourable business climate. [od.tax.gov.ua]

At the same time, following control and verification measures, the directorate blocked (prevented) refunds of UAH 43.7 million to 36 enterprises during the period — positioned as proof of transparent VAT administration and prompt processing of refund claims in line with the statutory chronological order (Art. 200 of the Tax Code). [od.tax.gov.ua], [od.tax.gov.ua]

This regional picture sits against a more mixed national backdrop: earlier in 2026, media reported the State Tax Service missing monthly VAT collection targets and a stock of non-refunded VAT exceeding UAH 30 billion nationwide — a reminder that refund timeliness remains a live issue for businesses. [forbes.ua]

Sources / external links: