The authorities are already preparing for the possible resumption of civil flights and are working out scenarios for airport operations amid security risks. At the same time, civil aviation itself, which is supposed to be the first to return to Ukraine’s skies, continues to operate under extremely difficult economic conditions and is facing additional pressure because of the treatment of aircraft leasing from non-residents as royalties for tax purposes, UNN writes.
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Is there a task to open the skies? There is. What are the priorities here? People’s safety. Will we prepare for the opening? This work is already under way! We have calculated all the algorithms to prevent, God forbid, an emergency. It is better to forecast 5, 15, or 100 action plans in advance. And that is what we are doing now
At the same time, Kalashnyk did not name any specific timeframe for reopening the skies.
The minister drew attention to the experience of Israel and African countries, where civil aviation continues to operate despite wartime risks. According to him, Ukraine is studying the experience of these countries and will also exchange experience with the International Civil Aviation Organization (ICAO), which regulates flight procedures.
He clarified that work is currently under way to organize safe spaces and shelters, provide alternative sources of electricity, and so on.
So this work is being carried out. It will definitely happen. It is simply a matter of time. Either the hostilities will end earlier with our great Ukrainian victory and peace will come, or civil aviation will resume during the period in which we are preparing for this
While airports are being prepared, the aviation industry is trying to survive
Obviously, reopening the skies is not enough. There must be those who return to them. After the airspace is reopened, Ukrainian carriers will have to compete with major foreign airlines. But Ukrainian airlines themselves have the potential to quickly return to the domestic market, restore jobs and increase tax revenues, as well as provide the country with its own aviation capacity.
Therefore, alongside the preparation of airports, shelters, and security procedures, another question arises: what condition will Ukrainian civil aviation itself be in by the time the skies reopen? This is where the situation remains difficult. Because of the war, Ukrainian civil aviation was forced to relocate abroad, where international contracts enable it to retain its personnel, certificates, and the airworthiness of its aircraft.
At the same time, the aviation business traditionally operates with low profitability and significant fixed costs. Aircraft require maintenance regardless of how intensively they are used, while carriers incur expenses for insurance, aircraft leasing, crew training, maintaining certificates, and compliance with international requirements.
Against this backdrop, another risk has emerged for the industry – an unexpected change in the approach of government bodies to the taxation of aircraft-leasing transactions with non-residents, without any change to the legislative framework.
More than 80% of Ukrainian airlines’ aircraft are leased
The issue of leasing is not a problem for an individual airline; it is systemic. As an earlier analysis by UNN of data from the State Register of Civil Aircraft showed, as of July 29, 2026, 27 private airlines operated 152 aircraft. Of these, 131, or 86%, were leased, while only 21 airplanes and helicopters (14%) belonged to the airlines themselves.
It is worth noting that all leased commercial aircraft are owned by foreign owners.
International leasing is one of the fundamental mechanisms on which global commercial aviation is built, and Ukraine is no exception. It is aircraft leasing that allows carriers to use expensive airplanes and helicopters without spending tens of millions of dollars purchasing them.
Under international law, in particular double taxation avoidance conventions, taxes on leasing are paid in the country where the lessor company is a resident, that is, abroad. In Ukraine, airlines pay other taxes and fees.
In particular, according to Danyil Menshikov, Head of the State Aviation Service of Ukraine, aviation industry companies paid almost UAH 27 billion in taxes and fees to the budget in 2022–2025, despite the closure of Ukrainian airspace.
Leasing began to be interpreted as royalties
Representatives of the aviation industry have long been drawing attention to the problem of the new interpretation by government authorities of leasing payments made to non-residents, which emerged without any amendments to tax legislation or international double taxation avoidance conventions. As UNN previously reported, since 2024 the Bureau of Economic Security has begun interpreting transactions involving the leasing of air transport from non-residents of Ukraine as the use of equipment. According to the investigators’ version, Ukrainian air carriers were supposed to pay royalties for the rental of aircraft and helicopters. Based on this approach, the BES opened criminal proceedings against at least five air carriers, including UIA, Constanta Airline, Windrose, H3Operations, and Skyline Express. According to UNN, another airline—Urga—may also feature in a similar case.
The criminal cases were opened despite the fact that almost all air carriers had successfully undergone 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 legal provisions and requires the establishment of a unified state approach. Moreover, interpreting aircraft leasing as royalties—a practice that does not exist in any other country in the world—makes Ukrainian carriers uncompetitive in the international market.
The average profitability of airlines today is only 7–10%, while additional taxation of leasing payments may reach 10–15%, depending on the lessor’s jurisdiction.
Earlier, in response to a request from UNN, the Ministry of Finance reported 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 possibility of taxing aircraft leasing as royalties.
Therefore, representatives of the aviation industry call the Bureau’s approach of interpreting aircraft leasing without amending tax legislation pressure that could destroy the entire passenger and freight transportation sector.
To resolve the situation, the issue of aircraft leasing was submitted for consideration by the Committee on Tax Policy, Accounting and Auditing 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 Ministry of Finance, which is to develop a draft general tax consultation on the taxation of leasing payments made to non-residents.
This mechanism could regulate the situation regarding the taxation of leasing and establish uniform, clear rules of the game for the aviation business that would comply with the Tax Code of Ukraine and international law.