The Minimum Tax Obligation (MTO) for land plots in 2026 should be calculated proportionally to the actual period of ownership or use of the land. This position was expressed by the Ministry of Finance of Ukraine in response to an inquiry from the State Tax Service of Ukraine. This was reported by the Main Department of the STS in Sumy region, referring to official explanations regarding the application of the norms of paragraph 74 of subsection 10 of section XX "Transitional Provisions" of the Tax Code of Ukraine.
The essence of the issue
According to the Tax Code, the amount of MTO cannot be less than:
700 UAH per 1 ha – for land plots of general purpose;
1,400 UAH per 1 ha – for lands where the share of arable land is not less than 50%.
In the letter from the STS dated November 11, 2025, it was noted that the current version of the transitional provisions of the Tax Code does not provide for adjusting the MTO depending on the number of months of land ownership, which formally meant the application of the full annual amount of MTO regardless of the period of land use.
At the same time, tax authorities pointed out that such an approach violates the principle of equality of taxpayers and may lead to double taxation of the same land plot in case of a change of owner or user during the year.
Ministry of Finance's position
In a letter dated February 2, 2026, the Ministry of Finance emphasized that the maximum amount of MTO (700 or 1,400 UAH/ha) should be adjusted proportionally to the number of months of actual ownership or use of the land plot during the tax year.
Thus, taxpayers should calculate the MTO only for the period during which they actually owned or used the land, rather than for the full calendar year.
The STS urges taxpayers to take this clarification into account when submitting tax reports and calculating the MTO for 2026 to avoid errors and potential tax disputes.
