We call for an end to the tax pressure and the effective dismantling of the Carpathian Biosphere Reserve

The Carpathian Biosphere Reserve includes the Chornohora range and Hoverla, the Maramureș massif, the Valley of Narcissi, and many other unique places of the Ukrainian Carpathians. It is home to rare plants and landscapes that form part of Ukraine’s identity and are the property of the Ukrainian people.

For half a century, the Carpathian Biosphere Reserve has been protecting and researching these unique Carpathian ecosystems.

For several years now, instead of focusing on its core mission — protecting and conserving unique ecosystems and developing recreational activities — the state institution Carpathian Biosphere Reserve has been forced to spend its efforts on court cases against another state body — the tax authorities of Zakarpattia and local communities.

The dispute concerns the right to a land tax exemption. In practice, the issue concerns state budget funds that local communities seek to obtain either as land tax payments or as compensation if the legally established tax exemption is applied.

The reserve is not a manager of budget funds and operates only through the State Treasury Service according to approved budgets.

In this situation, the state is not facilitating a resolution or ensuring the implementation of legal requirements.
As a result, the reserve’s accounts are being blocked, and attempts are being made to seize its property. This effectively threatens not only the administration of the Carpathian Biosphere Reserve but also the protected natural territories of the Carpathians under its care.

 The essence of the conflict

Under general rules, landowners and land users must pay land tax. However, the Tax Code of Ukraine exempts certain land users from this tax. As a scientific institution, the Carpathian Biosphere Reserve is entitled to such an exemption. If the state establishes a tax benefit that reduces revenues of other budgets, it must provide compensation mechanisms.

As a result, the reserve — a scientific and state-funded institution that cannot independently generate funds to pay land tax — has become a hostage of the situation:

• on one side, local communities where the reserve is located expect to receive passive income from the reserve’s lands (and over the last five years they have increased the land tax rate 1,000 times);
• on the other side, the state, which does not wish to fulfill the requirements of the Budget Code and compensate communities for land tax losses;
• the Ministry of Economy, Environment and Agriculture of Ukraine, which should ensure the uninterrupted functioning of such important institutions as the Carpathian Biosphere Reserve, has taken a passive position;
• the Main Department of the State Tax Service in Zakarpattia Oblast issued tax decisions against the reserve exceeding 58 million UAH (including penalties) following an inspection that failed to consider the complexity of the issue.

Tax authorities claim that the reserve allegedly lost its right to the land tax exemption because it provides paid recreational services (including recreational activities using recreational infrastructure) to the private company “OAZA”. However, these claims are unlawful.

Legal expert and lawyer of the Danube-Carpathian Programme, Sofiia Shutiak, explains:

Legality of services

Recreational activity in the zone of anthropogenic landscapes of the reserve is explicitly permitted by the Law of Ukraine “On the Nature Reserve Fund of Ukraine”, by Cabinet of Ministers Resolution No. 1913 on the list of paid services that budget institutions of protected areas may provide, and by the Ministry of Environment Order No. 256 (26 July 2022) on recreational activities within protected areas.
As a budget institution, the reserve has an approved budget for recreational services.

Status of the funds

Income from recreation is considered the institution’s own revenue and is transferred to the special fund of the state budget, where it may only be used for nature protection and research. This is not commercial profit-making activity and does not change the reserve’s status as a fully state-funded institution.

 Court proceedings

In disputes with communities, court decisions have been in favor of the reserve. However, in one case, on 12 March 2026, the Zakarpattia District Administrative Court rejected the reserve’s claim in the dispute with the tax authority, contradicting earlier decisions in disputes with communities. In our view, the court substituted legal concepts by equating a contract for recreational services with land lease, which is legally incorrect. The reserve has filed an appeal, and the process is ongoing.

A test for Ukraine

We believe this conflict has a political dimension. Its root cause is the state’s unwillingness to implement the provisions of the Budget Code that require compensation to local communities for tax exemptions granted to protected areas. Instead of addressing the issue directly with communities, the state shifts the burden onto the reserve, fueling local and regional conflicts during wartime. This is extremely dangerous.

We call on authorities to stop putting pressure on this conservation institution and ensure conditions in which the reserve can fulfill its main mission — protecting unique Carpathian ecosystems in accordance with national and international obligations and developing sustainable recreation.

State authorities must ensure the uninterrupted functioning of institutions such as the Carpathian Biosphere Reserve in order to protect the most valuable natural areas, rather than contribute to their destruction.

The case of the Carpathian Biosphere Reserve is a test for Ukraine — a test of adherence to the rule of law and respect for environmental commitments to the international community.