In 2025, international tax transparency took another step forward, and this time it directly affected Ukrainian citizens living abroad. From July 1, Germany will begin the automatic exchange of bank information with Ukrainian tax authorities. This applies to financial accounts of Ukrainians in German banks, insurance companies and investment institutions. For those who have found temporary protection in Germany or have been living here for a long time, this decision means a new level of transparency regarding their financial situation. And at the same time — new obligations and risks.
The legal basis of the decision
On May 23, 2025, the Bundesrat — the upper house of the German parliament — officially approved Resolution No. 155/25, which included Ukraine in the list of countries with which Germany automatically exchanges tax data according to the Common Reporting Standard (CRS). Thus, Ukraine became one of the 41 countries to which Germany will send information about foreign account holders in its financial system. The updated list also includes Armenia, Moldova and Uganda.
The decision is based on the multilateral agreement on the exchange of tax information, which the participating countries signed on October 29, 2014 under the auspices of the Organization for Economic Cooperation and Development (OECD). Ukraine joined this agreement in 2023, but only now — after finalizing the technical infrastructure for receiving information — the exchange became possible in practice.
What is the Common Reporting Standard (CRS)
CRS is a global financial reporting standard introduced by the OECD to combat tax evasion by opening foreign bank accounts. The participants of this system undertake to annually provide the tax authorities of other countries with information about the accounts belonging to their citizens or tax residents. Data transfer occurs automatically, without additional requests from the receiving country.
This information includes:
- availability of the account and its balance;
- earnings from investments, including dividends and interest;
- data on corporate account holders;
- identification data of the account holder.
How will it affect Ukrainian refugees in Germany
With the introduction of the exchange with Ukraine, the tax authorities of our country will have access to information about the accounts of their citizens in German financial institutions. For those who moved to Germany after the outbreak of full-scale war, this could be an important factor, especially if people maintain Ukrainian tax residency.
As of 2025, the majority of Ukrainian refugees in Germany continue to be considered tax residents of Ukraine, since they are not registered as residents of Germany and do not have an official waiver of the Ukrainian tax reference. This means that their obligation to declare income — including income received abroad — remains valid.
Now Ukrainian tax services will be able to independently receive data on:
- account balances in German banks;
- payments received from insurance policies;
- investment income, if any;
- holding accounts within firms or businesses registered in Germany.
This can have consequences both in the form of additional checks and fines in case of non-compliance or hidden income.
What should be done now
If you are in Germany and have a bank account, don’t put off checking your tax status. If you have not officially become a resident of Germany, you automatically remain a resident of Ukraine — and are subject to the obligation to submit a tax return.
In addition, it is important:
- check actual income with those declared in Ukraine;
- consult with a tax law or audit professional regarding possible risks, particularly in the context of CRS;
- if necessary, submit a corrected declaration in Ukraine or issue an official change of residence status.
Germany’s decision to include Ukraine in the CRS system is part of a broader trend of strengthening tax transparency in Europe. For Ukrainian citizens who temporarily or long-term reside in Germany, it means that the transition to legal schemes for storing funds and declaring income is no longer a voluntary choice, but becomes an almost inevitable requirement. Therefore, adapting to the new rules is not only a legal obligation, but also a form of financial security.
