Ukrainian airlines engaged in passenger and cargo transportation lease 86% of their aircraft and helicopters from foreign lessors. These data are important amid criminal proceedings of the Bureau of Economic Security, in which law enforcement interprets lease payments for aircraft as royalties. The new approach to interpreting lease transactions threatens the functioning of almost the entire civil aviation industry, reports UNN.
According to data from the State Register of Civil Aircraft of Ukraine, private Ukrainian carriers operate flights mainly on leased aircraft. As of July 29, 2026, 27 private airlines operate 152 aircraft. Of these, 131, or 86%, are leased, while only 21 aircraft and helicopters (14%) are owned by the airlines themselves.
The largest leased fleet among passenger airlines is held by "Rose of Winds," which operates 16 leased aircraft. The aircraft belong to nine different international lessors registered in Brazil, Ireland, Lithuania, the UAE, Cyprus, and Portugal.
In second place by the number of leased aircraft is the airline "Ukrainian Helicopters." The carrier uses 14 helicopters of the Mi-8/17 types, all of which are leased from four foreign companies.
Third place is occupied by Skyline Express with 13 leased Boeing aircraft of various modifications. The main owners of the aircraft are leasing companies from Ireland, Bermuda, and Turkey.
A number of cargo carriers and helicopter operators also operate entirely on leased fleets. In particular, H3Operations operates ten leased helicopters, "Constanta Airlines" – ten An-26, An-74, and Boeing 737 aircraft, "Kavok Air" – nine An-12 aircraft, "Vulkan Air" – eight An-26s, and the airline "Urga" – five SAAB 340B aircraft.
In addition, leased aircraft are used by SkyUp, MAU, Supernova Airlines, "Ukrainian Wings," "Yaneir LTD," Air Ocean Airlines, and other Ukrainian carriers.
Overall, the owners of aircraft and helicopters of Ukrainian carriers are companies registered in the UAE, Ireland, the UK, the USA, Brazil, Switzerland, Turkey, Singapore, Bermuda, Cyprus, South Africa, Moldova, Romania, Lithuania, Estonia, Scotland, and a number of other countries.
It is worth noting that the aviation fleet in Ukraine as a whole numbers 630 aircraft. This includes aircraft used in agriculture, training aircraft and helicopters, etc. Of these, 158, or 25%, are under official lease, where the owner and operator are different legal entities. At the same time, 100% of the lessors are foreign companies.
Let us add
Experts note that aircraft leasing is a common global practice, as the acquisition of modern aircraft requires significant capital investments, so most airlines use financial or operational leasing.
Despite this, the Bureau of Economic Security is investigating criminal proceedings against at least 5 airlines, including MAU, "Constanta Airlines," "Urga," H3Operations, and "Skyline" for allegedly failing to pay an additional 15% tax on non-resident income under aircraft and helicopter lease agreements. BEB investigators equate lease payments to royalties and interpret aircraft not as vehicles but as "equipment."
BEB received analytical conclusions after the previous team of the State Tax Service published an article in 2024 proposing to tax lease transactions with transport from non-residents of Ukraine as royalties. The documents formed the basis of criminal cases against air carriers.
However, according to lawyers surveyed by UNN, during the investigation, investigators ignore existing international conventions on the avoidance of double taxation. Treaties ratified by the Verkhovna Rada with foreign states take precedence over national legislation and determine in which state and at what rate the corresponding income of a non-resident may be taxed. Therefore, the automatic additional assessment of 15% in Ukraine without considering the provisions of a specific convention is at least controversial, experts emphasize.
It is worth noting that Ukrainian tax legislation regarding the taxation of leasing has not changed for decades. Moreover, according to the State Tax Service, airlines have undergone tax audits, and only based on the results of one of them was a violation established during the taxation of leasing. The remaining tax audits did not reveal such violations.
"Based on the results of one audit of companies in the aviation industry, leasing payments were reclassified as royalties. Only one audit," stated Viktoriia Kasian, Deputy Director of the Transfer Pricing Department of the State Tax Service of Ukraine.
However, the absence of violations did not prevent the Bureau of Economic Security from opening criminal cases against airlines, believing that they had not paid 15% royalties for the last 7 years. At the same time, the list of airlines against which law enforcement has claims regarding leasing may expand at any moment, since about 40 air carriers use leasing. Thus, the entire civil aviation industry could be under threat.