Anatoliy Kosovan, Managing Partner of Kosovan Legal Group, participated in a grain traders’ meeting organized by Trend&Hedge Club, during which the new Export Assurance Regime was discussed.
The event brought together representatives from the agricultural sector, including both business entities and state authorities, to address significant changes in export regulations. Participants examined the practical aspects of implementing the new procedure and its impact on company operations.
We share the key points from the discussion below:
• The most critical issue identified is the risk of suspension of the registration of the “export” tax invoice. This suspension would subsequently block the processing of the customs declaration, thereby making export impossible.
• To register such a tax invoice, a company must possess a sufficient tax invoice registration limit for the required amount.
• Utilizing newly established companies for export purposes solely to circumvent the rule regarding 20% unreturned foreign currency revenue is theoretically possible, but highly impractical, as the tax authorities will almost certainly block the registration of tax invoices for such companies.
• The 20% unreturned foreign currency revenue will be calculated not based on the total value of all goods supplied, but only on the portion for which the currency repatriation deadline has expired.
• The previous procedure involving verification and licensing for grain exports has effectively been abolished and is not planned for future application.
Such events are crucial for fostering constructive dialogue among market participants and finding solutions to the challenges faced by businesses.
Kosovan Legal Group continues to support clients in resolving legal issues aimed at maintaining business stability and complying with new requirements. Should you require legal consultation, please do not hesitate to contact us.


