Ukrainian air carriers are operating 131 leased aircraft out of a total of 152, which amounts to 86% of their fleet. The BBE is investigating cases against 5 airlines for classifying lease payments as royalties.
Ukrainian airlines engaged in passenger and cargo transportation lease 86% of their aircraft and helicopters from foreign lessors. This information is significant in light of criminal proceedings initiated by the Bureau of Economic Security, where law enforcement agencies are classifying lease payments for aircraft as royalties. This new interpretation of leasing operations jeopardizes the functioning of almost the entire civil aviation sector, reports UNN.
According to the State Register of Civil Aircraft of Ukraine, private Ukrainian air carriers predominantly operate leased aircraft. As of July 29, 2026, 27 private airlines operate 152 aircraft. Of these, 131, or 86%, are leased, while only 21 aircraft and helicopters (14%) are owned by the airlines themselves.
Windrose Airlines possesses the largest leased fleet among passenger carriers, operating 16 leased aircraft. These aircraft belong to nine different international lessors registered in Brazil, Ireland, Lithuania, the UAE, Cyprus, and Portugal.
Ukrainian Helicopters ranks second in terms of the number of leased aircraft. The carrier utilizes 14 Mi-8/17 type helicopters, all of which are leased from four foreign companies.
Skyline Express holds the third position with 13 leased Boeing aircraft of various modifications. The primary owners of these aircraft are leasing companies from Ireland, Bermuda, and Turkey.
A number of cargo carriers and helicopter operators also function entirely on leased fleets. Specifically, H3Operations operates ten leased helicopters, Avia Company Constanta operates ten An-26, An-74, and Boeing 737 aircraft, Kavok Air operates nine An-12 aircraft, Vulcan Air operates eight An-26 aircraft, and Urga airline operates five SAAB 340B aircraft.
Additionally, leased aircraft are used by SkyUp, МАУ, Supernova Airlines, Ukrainian Wings, Yanair LTD, Air Ocean Airlines, and other Ukrainian carriers.
Overall, the owners of aircraft and helicopters operated by Ukrainian air carriers are companies registered in the UAE, Ireland, the UK, the USA, Brazil, Switzerland, Turkey, Singapore, Bermuda, Cyprus, South Africa, Moldova, Romania, Lithuania, Estonia, Scotland, and several other countries.
It is noteworthy that the total aviation fleet in Ukraine comprises 630 aircraft. This includes aircraft used in agriculture, training aircraft, and helicopters, among others. Of these, 158, or 25%, are under official lease agreements where the owner and operator are different legal entities. Furthermore, 100% of the lessors are foreign companies.
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Experts point out that aircraft leasing is a globally accepted practice, as acquiring modern aircraft requires substantial capital investment, leading most airlines to utilize financial or operational leasing.
Despite this, the Bureau of Economic Security is investigating criminal proceedings against at least 5 airlines, including МАУ, Avia Company Constanta, Urga, H3Operations, and Skyline, for allegedly failing to pay an additional 15% tax on non-resident income to the Ukrainian budget under aircraft and helicopter lease agreements. The BBE investigators equate lease payments to royalties and classify aircraft not as means of transport but as “equipment.”
The BBE received analytical conclusions after a previous DPS team published an article in 2024 proposing to tax leasing operations involving non-resident transport as royalties. These documents formed the basis for criminal cases against air carriers.
However, according to lawyers interviewed by UNN, investigators are disregarding current international double taxation avoidance conventions during their inquiries. Treaties ratified by the Verkhovna Rada with foreign states take precedence over national legislation and stipulate in which country and at what rate a non-resident’s income can be taxed. Therefore, the automatic assessment of an additional 15% in Ukraine without considering the provisions of the specific convention is, at the very least, controversial, experts emphasize.
It is worth noting that Ukrainian tax legislation concerning leasing taxation has remained unchanged for decades. Moreover, according to the State Tax Service, airlines have undergone tax audits, and only one of these resulted in the identification of violations in lease taxation. The remaining tax audits did not reveal such infringements.
“Following one audit concerning companies in the aviation industry, lease payments were reclassified as royalties. Only one audit,” stated Viktoriia Kasiian, Deputy Director of the Transfer Pricing Department of the State Tax Service of Ukraine.
Nevertheless, the absence of violations did not prevent the BBE from opening criminal cases against airlines, alleging they have not paid 15% in royalties over the past 7 years. Meanwhile, the list of airlines facing claims from law enforcement agencies due to leasing may expand at any moment, as approximately 40 air carriers utilize leasing. Consequently, the entire civil aviation sector could be impacted.