142 Million in Half a Year: How the Shadow Hotel Market Became a Donor to Local Budgets

Record tourism collection in 2025 is not so much about more tourists, but rather about more payers: the unified transaction registry is pulling out of the shadows those who have not paid anything for years.

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In the first half of 2025, tourism tax in Ukraine amounted to 142.6 million hryvnias — a record in the entire history of observations. Compared to the pre-war 2021, this is a plus 52%, compared to the same period in 2024 — plus one-third. The State Tourism Development Agency, responding to a LIGA.net request, named five reasons for the growth. But the most interesting one is not about tourism.

Money came not from new tourists, but from old non-payers

Until 2025, a significant part of the short-term rental market — apartments, estates, small hostels — existed outside the fiscal radar. Owners accepted cash or unofficial transfers, kept no records.

"Not all property owners who rent their premises to tourists operate officially, are registered, accept official payments and, accordingly, pay the tax. Therefore, the actual size of the market is significantly larger than recorded in the reports"

Denys Popov, lawyer and arbitration manager

The situation was changed by the implementation of a unified transaction registry under the control of the tax service. According to Popov, the shadow segment is gradually shrinking — and this is one of the key reasons for the surge in indicators in 2025.

The structure of taxpayers has changed

A few years ago, big business — hotels, sanatoriums, chain accommodation facilities — formed 62% of tourism tax revenues. Now it's 55%, and 45% is paid by apartment owners, estate owners and small facilities. The picture evened out not because hotels pay less, but because the small sector finally started paying more.

Geography has also been redrawn. Odesa, the pre-war leader, lost almost half of its revenues — a direct result of the war's impact on the south. Meanwhile, Bukovina, Prykarpattia and Cherkasy region grew three to four times: internally displaced persons and volunteers replaced foreign tourists, and local businesses adapted.

Tax mechanics: from minimum to invoice

The tourism tax rate is tied to the minimum wage as of January 1 of the current year. In 2025, this is up to 40 hryvnias per day for domestic tourism and up to 400 hryvnias for foreigners. Funds go exclusively to local budgets — no share in the state treasury. Rates are set by local councils by July 15 of the year preceding the budget year.

The increase in minimum wage since 2021 is one of the official factors in tax growth, as the maximum rate automatically increases with it. However, the rate increase alone would not be enough without expanding the taxpayer base.

Record is not yet final

According to Opendatabot, the peak of the tourism season is in the second half of the year. If the pace continues, 2025 will become an absolute record for domestic tourism revenues throughout independence.

The top three leaders remain unchanged: Kyiv, Lviv region and Ivano-Frankivsk region. In six regions, big business still dominates — in particular, in the capital, hotels account for 83% of all tax revenues.

The key question is not whether revenues will continue to grow — but whether the transaction registry will be sufficient to cover the entire market: if 45% of the small sector is still partially in the shadow, the actual tax base may be twice as large as what is currently visible in the STS reports.

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