The provisions of the Law of Ukraine “On Currency and Currency Transactions” of June 21, 2018, No. 2473-VIII, do not contain requirements for the declaration of currency values. Therefore, the declaration on currency values for reporting periods since the first quarter of 2019 is not filed. The last period for which it was necessary to file a declaration is 2018 (as of 01/01/2019).
If someone had doubts about the cancellation of the declaration on currency values, then with the advent of this consultation, they finally disappear. Separate semi-official consultations from the overseers appeared before, but their status did not cause much confidence.
Recall that these doubts were caused by the fact that the Law on Currency does not provide for the declaration of currency values and property that are outside Ukraine. This is so clear and does not cause confusion. The question was that this Law came into force on 07.02.2019. Declaring takes place quarterly as of the first day of the quarter. That is, strictly speaking, the period from January 1 to February 7 remained in limbo. Regarding this period, there was doubt: would the controlling bodies say that this period (or the whole first quarter as a transitional period) still needs to be closed with a declaration? We, for our part, see no reason for such fiscal conclusions, because declaration date (on the first day of the second quarter) the obligation to file a declaration will no longer be valid. Actually, this consultation is about this.
First, this is correct for formal reasons, which we have mentioned above.
Secondly, it is not the movement of currency values and property, so to speak, “for” a period, but their availability as of a certain date is declared. By itself, the date February 7 (or some other date, except the first day of the quarter) has no legal significance. Therefore, the declaration of the period from 01/01/2019 to 07/02/2019 is inherently incorrect. Well, about the whole first quarter (as of 01/01/2019) there can be no question.
As a result, we establish the fact: the latest currency declaration had to be filed within the deadlines set for filing financial reporting to the tax authorities as of 01/01/2019.