New Land Payment Rules: How Ownership Change Affects Tax Payments in 2025
Starting October 1, 2025, a new procedure for paying land fees in the event of a change of property owner came into force in Ukraine. The Law of Ukraine dated July 16, 2025, No. 4536-IX established these changes and clarified procedures affecting both landowners and users across the country.
The main innovation is the possibility of crediting previously paid amounts. Now, if the obligation to pay transfers to a new owner, the amount already paid by the previous payer can be credited as an advance for the new owner. This avoids double payment and simplifies financial settlements between the parties to the transaction.
However, the mechanism works under certain conditions:
- The new owner must reimburse the previously paid amount to the former payer.
- Reimbursement is made on the basis of a conclusion by the controlling authority (usually the tax service).
- The procedure prevents cases where two payers have paid for the same plot for the same period.
The State Tax Service of Ukraine emphasizes: “The new rules are aimed at simplifying the process of transferring the obligation to pay for land when changing the owner, avoiding double payment, and increasing the transparency of settlements with the budget.”
According to Article 120 of the Land Code of Ukraine:
- When ownership of a building, structure, or other object is acquired, the ownership right to the land plot under it automatically passes to the new owner.
- If the plot was leased, the right to use it also transfers to the acquirer.
The ownership or use right to the plot arises from the moment of state registration. From this day, the new owner or user is obliged to pay the land fee.
Law No. 4536-IX officially amended the Tax Code and a number of other laws to “improve certain provisions of tax legislation” and “prevent double payment.”
Motivation and Practical Implications for Owners and the Budget
In Ukraine, there have often been disputes between new and previous owners as to who should pay the land fee if part of the tax period has already been paid at the time of the title transfer. Because of this, the state sometimes received double payment, or owners had to resolve it through the courts.
Now:
- Financial obligations become transparent and regulated by law.
- The new owner clearly understands that their payments will not overlap with those already made by the predecessor.
- Local budgets receive predictable revenues no more and no less than required.
Details of the New Procedure: Who Pays and When
- The obligation to pay arises from the day of state registration of ownership or use.
- If the previous owner has already paid the tax, they may receive reimbursement from the new owner (but only after the conclusion of the controlling authority, which determines the amount to be credited).
- For this, both parties submit the relevant application and documents to the tax service.
Is This Really a Reform? Political Scientist’s Assessment
Law No. 4536-IX is a modest but systematic reform that aligns with the principles of fiscal fairness and transparency. It solves several problems:
- Reduces the administrative burden for new property owners.
- Minimizes the risk of double payment for the budget and citizens.
- Makes tax obligations predictable and protects both parties in the transaction.
The law takes into account the specifics of the Ukrainian real estate market, where transactions for the purchase and sale of land and buildings often coincide with taxes paid in advance or retroactively. The new mechanism reduces the risk of disputes and ensures stable budget revenues.
This reform is real, justified, and meets the current situation in Ukraine. It contributes to strengthening trust in the tax system and protecting the interests of both parties in real estate transactions. The introduction of a mechanism for crediting already paid amounts makes the process more transparent and efficient.
From the perspective of a political scientist, it is important to note:
- The state continues to move toward deregulation and digitalization of tax relations.
- Legal certainty in land issues has always been important for Ukraine, where land has strategic and emotional significance.
- The implemented changes reduce the basis for abuse and legal disputes.
Therefore, Law No. 4536-IX is a logical and timely step toward transparency, efficiency, and fairness in the management of land and real estate in Ukraine.
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