There is no direct official answer to this question. Whether taxable income arises when you swap one cryptocurrency for another and withdraw no hryvnia is stated neither in the Tax Code nor in State Tax Service guidance.
We looked for guidance that answers this directly and found none. Everything available online is interpretation, and below we show what each version is built from.
A word up front about the limits of this text. We are an exchange service, not a tax adviser. What follows summarises what we were able to verify and names what we were not. An answer the state does not have is not one we have either.
Why the question arose at all
The question comes out of the arithmetic. An active trader makes dozens, sometimes hundreds of operations inside the market: bitcoin into a stablecoin, stablecoin into an altcoin, back into a stablecoin.
They never see a hryvnia along the way. And if every such operation counts as income, the total assessed comes out larger than everything on the balance put together.
The fear is not imaginary. State Tax Service guidance speaks of taxing the entire sum of funds received from cryptocurrency operations, with no deduction for costs: the investment income rules are not applied to crypto, because it is not recognised as an investment asset.
Apply that same formula mechanically to every internal swap and the result is absurd. But whether it applies that way is stated nowhere.
What the logic of the existing guidance suggests
The State Tax Service wording refers to the sum of funds received from operations. In tax language, funds means money, not assets in general.
That is where the first common interpretation comes from: the event that creates income is the moment you received money, and swapping one asset for another is not that moment.
And here is the central caveat: this is an interpretation, not the tax authority's position. Nowhere has the State Tax Service said that crypto-to-crypto swaps are not taxed. It said something else about something else, and the conclusion about internal swaps was drawn by readers, lawyers and article writers among them. The conclusion looks reasonable. It has no status.
Matters are complicated by the fact that the State Tax Service position itself is not anchored in a provision of the Code. The Tax Code contains no direct rules on taxing this kind of income, only guidance exists.
We were unable to verify the dates of that guidance: the tax authority's site returns an access error to a direct request. So the interpretation rests on a document that is not itself the law.
What the unadopted bill proposes
Bill No. 10225-d answers the question directly: conversion into fiat is taxed, while swapping one cryptocurrency for another is not. That is where the confident tone of the online articles saying there is no tax comes from.
The bill has not been adopted. Per its card on the Verkhovna Rada site: registered on 24 April 2025, adopted at first reading on 3 September 2025, then in preparation for a second reading. The card records no event after September 2025. Adoption has been postponed, and the most recent mention puts it off to the autumn at the earliest.
You cannot rely on such a text, for two reasons. First, it is not law in force, and it does not determine the tax consequences of today's operations.
Second, this is the first reading version, and the wording may change before the second reading. The text prepared for the second reading is not publicly available, so we cannot even say whether this provision has survived in it.
Why we do not write that there is no tax
Because we do not know that, and the cost of being wrong does not fall on us. Both versions, that income arises only on receipt of money and that the bill expressly exempts swaps, sound convincing, and neither is the state's answer.
If the tax authority later takes a different position, it is the reader who receives the assessment, not the author of the article.
An exchange service that passes off a guess as an answer does its readers no favours. So the wording here is deliberately uncomfortable: the question is open. It can be closed by guidance that answers it directly, or by an adopted law. As of now there is neither.
What to do until there is clarity
Keep your operation history. This is the one piece of advice that works whatever the outcome: if swaps are treated as an income-creating event, the history will be needed for the calculation; if they are not, it will be needed to prove where the amount came from at the point of withdrawal into hryvnia.
In practice that means exporting your full history from the exchange once a quarter and storing it locally, rather than counting on account access.
Alongside it, keep proof of the original purchase: that is what answers the question about the source of funds when a bank asks it.
And one last thing. If your volume of operations is such that the difference between the two readings is measured in real money, that is a question for an accountant who can see your specific case, not for an article. We are an exchange service, not a tax adviser, and we do not make decisions with those consequences on your behalf.
