Ukraine: VAT Consequences for Commission Goods Destroyed at Warehouse

In a commission-sale arrangement, transferring goods to the commission agent is treated as a VAT supply for tax purposes, so the principal must accrue VAT and issue a tax invoice on the transfer date, even though civil law keeps ownership with the principal until resale.
If the goods are later destroyed or lost at the commission agent’s warehouse, including due to shelling/force majeure, the tax authority says the principal has no grounds to adjust VAT liabilities under Article 192 of the Tax Code and cannot issue a corrective adjustment to the original invoice.
The basis for this position is that Article 192 allows corrections only for specific cases: change in compensation amount, return of goods/services, or return of an advance payment.
The article indicates that the civil-law ownership rule does not affect VAT treatment in this context; what matters is the initial deemed supply when goods were handed over to the commission agent.

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.