TAXATION SYSTEM TRANSFORMATION FOR DIGITAL ASSETS IN UKRAINE AMIDST THE PILLAR TWO GLOBAL TAX REFORM IMPLEMENTATION

Abstract

This article presents a comprehensive study of the mechanisms for implementing the Pillar Two global tax reform within Ukraine's legal and economic framework as of 2026. Particular attention is paid to the GloBE (Global Anti-Base Erosion) mechanism, which introduces a hierarchy of rules: QDMTT (domestic tax), IIR (inclusion of income at the parent company level), and UTPR (safeguard rule). It is determined that for multinational enterprise groups (MEGs) with consolidated revenue exceeding 750 million euros, the tax base is now determined exclusively according to IFRS with a number of specific adjustments, which effectively neutralizes the competitive advantages of traditional «tax havens» and offshore instruments. The study pays particular attention to identifying critical risks for residents of the special legal regime «Diy.City». Since the current capital gains tax (CGT) rate of 9% is significantly lower than the established global minimum (15%), there is a real threat that other jurisdictions will capture the tax benefit through the Top-up Tax mechanism. It has been demonstrated that the current preferential capital gains tax (CGT) rate of 9% sets a precedent for low taxation (below the global minimum of 15%), which, in the absence of adaptive mechanisms, will lead to the withdrawal of tax benefits by other jurisdictions through the Top-up Tax mechanism. It is argued that Ukraine's implementation of its own QDMTT mechanism is a strategic step that will allow tax revenues from the activities of Ukrainian IT talent to remain in the state budget, preventing their redistribution to the benefit of the countries where corporate headquarters are located. A methodological analysis revealed significant discrepancies between the National Accounting Standards (NAS) and the GloBE rules regarding consolidation (Jurisdictional Blending), deferred tax accounting, and the valuation of crypto-assets. The author proposes three strategic directions for adapting businesses to the new realities: conducting systematic Impact Assessments (assessments of the impact on financial condition), revising transfer pricing policies, and preparing IT infrastructure for GIR reporting. The conclusion is that Pillar Two is effectively transforming into a «third accounting system», requiring deep integration of tax planning with IFRS to ensure Ukraine's investment attractiveness and international image as a transparent digital jurisdiction.