Ukraine’s budget is facing a severe shortage of funds: over the first eight months of 2026, general fund revenue targets were underfulfilled by UAH 33.1 billion. The Government is already warning of the need to restrict spending, while delays in international financing are creating additional risks for the economy. Under these circumstances, preserving businesses that continue to operate in Ukraine and contribute to the state budget is particularly important, UNN writes.
The budget received more than UAH 33 billion less than expected
According to Roksolana Pidlasa, Chair of the Verkhovna Rada Committee on Budget Issues, the state budget received UAH 33.1 billion less than expected in January–August 2026.
According to operational data, over the first eight months of 2026, UAH 1.7 trillion was credited to state budget general fund revenues (EXCLUDING grants). The shortfall against the target amounted to UAH 33.1 billion, almost half of which (UAH 15.6 billion) failed to come in specifically in August 2026
Pidlasa added that the combined shortfall against the target for the main budget-forming taxes and fees amounted to almost UAH 84 billion.
The situation is particularly sensitive given the structure of state spending. Over the first eight months, UAH 1.8 trillion was allocated to defense, accounting for 62% of all general fund expenditures. Hundreds of billions more are needed to repay and service the public debt, as well as for social protection, healthcare, and education.
The delay in external financing has become an additional risk for the Ukrainian economy. Parliament was unable to adopt the legislative decisions necessary to receive a $4.26 billion macro-financial assistance tranche and $1.66 billion in IMF financing. President of Ukraine Volodymyr Zelenskyy called on members of parliament to support the bills necessary to finance the budget deficit
The Government is forced to economize
Finance Minister Serhii Marchenko forecasts a budget deficit of up to $32.6 billion. He said that, due to problems with the receipt of international assistance, the Government had been forced to begin restricting expenditures.
We are forced to apply measures to restrict expenditures
According to the minister, all non-critical expenditures have already been postponed until December, and the state will operate under conditions of limited liquidity. Financing the security and defense sector will remain the priority, while other expenditures will be made depending on the availability of resources. Thus, the Finance Ministry chief did not rule out delays in salary payments.
We have prepared the relevant regulations governing our actions during a period of limited liquidity. First and foremost, we finance the security and defense sector. As soon as additional sources of financing become available, we finance all other expenditures (…) Any construction programs, including social construction, will be suspended until we have sufficient liquidity to finance them
He also did not rule out monetary financing of the budget, which could lead to the devaluation of the hryvnia and accelerate inflation.
Thus, the Government’s task now is not only to seek new sources of funding, but also to preserve as much as possible the existing tax base—that is, businesses that operate, create jobs, and regularly contribute to the state budget.
Almost UAH 27 billion from the aviation industry even with the skies closed
One such industry, despite the skies over Ukraine being closed because of the war, is aviation. Since the beginning of the full-scale invasion, aviation industry enterprises have continued to operate and contribute to the budget.
According to Daniil Menshikov, head of the State Aviation Service, aviation industry enterprises paid almost UAH 27 billion in taxes and fees to the budget in 2022–2025.
It is also important to speak in terms of facts: Ukrainian airlines continue to pay taxes. According to information provided by the State Tax Service, in 2022–2025 the industry paid almost UAH 27 billion in taxes and fees to the budget
And this was happening at a time when the domestic air transport market was virtually nonexistent, companies were forced to relocate abroad, and their operations were being complicated by the need for additional insurance and financing, as well as the restructuring of logistics and maintenance.
Despite this, air carriers managed to preserve their operations by working in international markets and continued to contribute to the state budget.
Claims against airlines over aircraft leasing
Against this backdrop, the situation surrounding the taxation of aircraft leasing looks particularly dangerous.
As UNN previously reported, the problem arose because of a new approach to interpreting the leasing payments made by Ukrainian airlines to nonresidents. Since 2024, the Bureau of Economic Security has begun treating them as royalties, although no corresponding changes to the legislation have been made.
According to the investigators’ version, Ukrainian air carriers were supposed to pay royalties for leasing aircraft and helicopters. Based on this approach, the BES opened criminal proceedings against at least five air carriers, including MAU, "Constanta Airline," "Wind Rose," H3Operations, and "Skyline Express." According to UNN, another airline—"Urga"—may also be involved in a similar case.
The criminal cases were opened despite the fact that almost all air carriers had successfully passed tax audits, and the tax authorities’ comments concerning leasing applied to only one company.
Representatives of the aviation industry insist that the problem arose because of an ambiguous interpretation of the legislative provisions and that it requires the establishment of a unified state approach.
The Head of the State Aviation Service warned that the consequences of such an approach extend far beyond the problems of individual enterprises. According to the State Register of Civil Aircraft of Ukraine, 86% of the aircraft fleet of Ukrainian companies is leased.
Such an approach creates risks not for an individual company but for the entire aviation industry. Ukrainian airlines are already operating amid extraordinary challenges: the airspace is closed, markets have been lost or significantly restricted, and operations have been complicated by the war, financing, insurance, and maintenance issues. Despite this, the industry has not stopped. It is adapting, surviving, and continuing to operate under extremely difficult conditions, demonstrating resilience that commands the respect of the entire world
At the same time, an analysis of the financial statements of aviation market participants shows that a significant proportion of companies are operating at a loss. Even those air carriers that have so far managed to remain profitable are showing a sharp decline in profitability and margins.
The reasons for the decline are obvious: the closure of Ukrainian airspace, the need to relocate personnel and fleets, rising operating costs, difficulties operating in international markets, and overall economic instability.
Despite this, companies continue to retain personnel, preserve their flight and technical staff, maintain certification, and fulfill their obligations to the state. In addition, private aircraft-manufacturing enterprises have remained operational in Ukraine, currently focusing on the repair of military equipment. They are being sustained through state contracts as well as financial contributions from airlines.
That is why any additional pressure on the industry, both fiscal and criminal, is much more dangerous today than it was several years ago. Whereas enterprises could previously offset such risks through profitability, many are now operating with minimal financial resilience.
Moreover, paying royalties for leasing transactions would automatically make Ukrainian airlines uncompetitive in the international market. The use of leased aircraft fleets is a global practice, and lessors will obviously favor companies operating in jurisdictions that follow international law and apply clear approaches to taxation.
What the Finance Ministry Says About Aircraft Leasing
In response to a request from UNN, the Ministry of Finance said that the taxation of aircraft leasing transactions is carried out in accordance with the Tax Code and Ukraine’s international treaties. At the same time, the Tax Code of Ukraine does not provide for the taxation of aircraft leasing as royalties. Therefore, the Bureau’s approach to interpreting aircraft leasing without amending tax legislation is described as pressure that could destroy an entire sector of passenger and freight transportation.
That is why the issue of aircraft leasing was submitted for consideration by the Tax Committee of the Public Council under the Ministry of Finance. Following the first meeting, it was decided to initiate the creation of a working group under the Finance Ministry that would develop a draft generalized tax consultation on the taxation of lease payments made to non-residents.
The document will not automatically cancel liability, but it will confirm the ambiguity in the interpretation of aircraft leasing taxation and become an argument in disputes.
The Finance Ministry issues generalized tax consultations, in particular, when circumstances indicate that a provision is ambiguous. In other words, the state has officially certified by its own order that the provision is ambiguous. And this is a direct bridge to subparagraph 4.1.4 and paragraph 56.21 of the Tax Code — the presumption that a taxpayer’s decisions are lawful where there are multiple interpretations. Sometimes a generalized tax consultation is more useful as evidence of the fog than as a source of light
In conditions of a severe budget deficit, the state cannot afford to lose taxpayers because of legal uncertainty and excessive pressure. The Ministry of Finance is clearly aware of this as well, and has therefore begun addressing the issue of aircraft leasing. The ministry understands that airlines which continue to contribute to the budget even during the war must be given the opportunity to operate stably in Ukraine under clear rules.
The Budget Needs Taxpayers, Not New Problems for Business
The situation is quite contradictory: on the one hand, the state urgently needs money, is seeking additional sources to finance the budget deficit, and has already been forced to limit some expenditures; on the other hand, one of the profitable sectors, which has brought nearly UAH 27 billion to the budget, is facing pressure and is at risk of being destroyed.
In the short term, fiscal pressure on air carriers may appear to be a way to generate additional revenues. However, if it results in companies losing their solvency, curtailing their operations, or leaving the Ukrainian jurisdiction, the budget risks losing not only potential additional assessments, but also stable tax revenues in the future.
Nor should we forget that wars eventually end, and civil aviation links will be restored in post-war Ukraine. Therefore, it is important that Ukrainian airlines themselves return to Ukrainian skies and, consequently, create jobs, continue generating foreign-currency revenue, and contribute to the budget.
Ukrainian airlines will be the first to enter the market after the opening of the skies. That is why we need clear rules for everyone. I am convinced that such issues should be resolved through professional dialogue among the state, business, associations, and the expert community. What is needed is unity of approach, legal certainty, and decisions that take into account the strategic importance of aviation for Ukraine
When every billion in budget revenues is critically important, the state’s task is not only to seek new taxes or sources of borrowing. It is equally important to preserve those taxpayers that are already contributing to the budget. Therefore, resolving the problem of aircraft leasing taxation, ending the practice of legal uncertainty and excessive pressure on airlines is not merely a matter of survival for a particular sector; it is a matter of preserving businesses that continue to operate and pay taxes.