In Germany, the share of companies in the used car trade is over 70%, and in Poland, it is at least 20%. According to official statistics in Ukraine, only 2.6% of cars were purchased by legal entities in 2022, but in practice, we see many sales sites on the streets, and their number is growing. Such companies sell used cars but are not included in official statistics. Why is this happening? Who actually sells cars, what is the difference between official statistics and reality, and what can change this? The experts of the Automotive Market Research Institute, together with analysts from YouControl.Market and Automoto.ua analysed the data sets and found the answers.
What is the volume of car business in Ukraine?
In 2022, Ukrainians bought 100.7 thousand new cars: 71.3% were imported from abroad (71.8 thousand), and another 28.7% were manufactured or re-equipped in Ukraine (28.9 thousand). There are networks of official importers and dealers that sell new cars and report on their activities. This segment is generally transparent and understandable, unlike used car sales, experts of the Automotive Market Research Institute say.
Last year, almost 1.3 million sale and purchase transactions of used vehicles were registered in Ukraine. Of these, 36.3% were first registered after import from abroad (463.1 thousand), and 63.7% (811 thousand) were domestic resales.
At the same time, in the domestic market, only in 2.6% of cases, legal entities, i.e. companies, were the party to the transaction (the final buyer) (21.1 thousand transactions). In the remaining 97.4% of cases (789.9 thousand), cars were registered to individuals, i.e. ordinary citizens.
When analysing the place of contract conclusion, only 66.8% of cases were made at the Service Centres of the Ministry of Internal Affairs, where this service is free to individuals. Therefore, most will likely be direct sales from the previous owner to the new one, the actual share of sales by ordinary citizens who sell their cars every few years.
At the same time, 32.8% of agreements were made on commission platforms. That is a type of agreement where a retailer registered with the Main Service Centre of the Ministry of Internal Affairs provides a commission sale service and is not a party to the agreement. From a legal point of view, this is only a support service: that is, the company brought the seller and the buyer together and recorded their agreement in the relevant electronic register, for which it received a commission. However, it was not an intermediate owner of the car and did not receive a margin, i.e., the difference between the purchase and sale price. Therefore, it will not pay tax on it; moreover, it will not bear any legal responsibility in case of the buyer's claims against the car.
Only 0.3% of cases (2.4 thousand) were vehicles sold by legal entities that owned them at the time of sale. And, most likely, it was the sale of cars from their fleet that were in operation rather than a sale and purchase transaction for profit.
For comparison, in neighbouring Poland, according to the Polish Automotive Market Research Institute IBRM Samar, in 2022, dealers (companies) sold 19.6% of the total number of cars on the domestic market. At the same time, according to experts, they also often use a scheme where a commission agreement is drawn up instead of a purchase and sale agreement, which means that the actual share of the business segment in used car sales in Poland is much higher.
In Germany, the share of business sales of used cars is 79%: in 2020, 48% of used cars were sold by official dealers, and another 31% by independent companies (so-called auto houses). Individuals sold only 21% of vehicles.
According to experts of the Automotive Market Research Institute, the main reason why the business segment of domestic resales of used cars in Ukraine may operate in the shadows, apart from the desire to evade taxes, is bureaucratic difficulties.
Today, a company that wants to provide a trade-in service – buying a used car from the previous owner for further resale – must register the vehicle with the Service Centre of the Ministry of Internal Affairs. That means obtaining a new registration certificate and license plates. They must also notify the local Territorial Center of Recruitment and Social Support of purchasing such a car. All these steps must be repeated when selling the vehicle to a new owner.
The automotive business does not buy cars to avoid such economically unreasonable transactions. Instead, it issues a notarized Power of Attorney for the car and signs a Commission Agreement during the sale, as described above.
The situation with the import of used cars in Ukraine is somewhat different. The law allows a legal entity to import a used vehicle without registering it with the Ministry of Internal Affairs Service Centre. That allows the car to be imported, put up for sale, and registered for the first time by the final buyer (individual or legal entity) after the purchase and receipt of the Sale Agreement from the company. If necessary, such trading organisations can issue temporary red licence plates, known as "transit plates," so the car can be driven to the registration location.
The created conditions are accordingly reflected in the registration statistics: the business segment and individuals are almost equally split. Thus, in 2022, 51% of used cars were imported from abroad by individuals (236,300) and 49% by companies (226,800). At the same time, almost all the cars imported by companies were subsequently sold to end buyers – individuals, in 92.1% of cases (209 thousand).
Therefore, among used car sales, the used car import segment can currently be considered the most transparent and the one that is closest to the actual share of the business segment in it.
Conclusion 1. In official statistics, a significant portion of internal resale of used cars, carried out by the business segment, is not reflected. A part of the automotive business (32.8%) enters into commission agreements instead of purchase and sale agreements. That is due to the complexity of bureaucratic procedures. The import of used cars is more transparent: almost half (49%) are officially imported by legal entities.
How much tax have car dealers paid?
To determine whether the automotive business is operating officially, it is necessary to analyse state registers. According to the current classification of economic activities, car dealers fall into two categories: 45.11 - Sale of cars and light motor vehicles and 45.19 - Sale of other motor vehicles. The sample included sellers of all vehicles – new and used, both imported from abroad and previously registered in Ukraine.
According to YouControl.Market analytical data: In 2022, 5,331 active companies (not in the process of termination) indicated one of these codes as their main activity. At the same time, only 1,288 of them filed financial statements with the specified income.
The most popular regions with registered companies engaged in the trade of motor vehicles were Kyivska (32.9%, 1,751), Volynska (5.8%, 310), Odeska (5.6%, 291), Kharkivska (5.4%, 286) and Dnipropetrovska (5.3%, 281) oblasts.
If we take into account only the companies that filed financial statements in 2022, the largest share of net income was recorded by organisations located in Kyiv (54.5%, 77 billion UAH of net income), Kyivska (17.2%, 24.4 billion UAH), Dnipropetrovska (4.2%, 5.9 billion UAH), Volynska (4.1%, 5.8 billion UAH) and Lvivska (3.5%, 4.9 billion UAH) oblasts. Notably, the capital and the region together accounted for 71.7% of the revenue structure.
The automotive businesses located in Khersonska (0.02%, 30.2 million UAH), Sumska (0.19%, 276.3 million UAH), Donetska (0.22%, 319.1 million UAH), Chernihivska (0.24%, 336 million UAH), and Zhytomyrska (0.38%, 546.5 million UAH) oblasts received the lowest net income last year.
Car dealers reported 142.3 billion UAH in net income in 2022.
If we consider net profits reported by car dealers last year, the biggest earners were car dealers in Kyiv (4.55 billion UAH), Kyivska (1.08 billion UAH), Lvivska (80.5 million UAH), Khmelnytska (45.7 million UAH) and Dnipropetrovska (26.3 million UAH) oblasts. Accordingly, these car dealers paid the most taxes.
Car dealers from Kharkivska (-98.8 million UAH), Odeska (-88.5 million UAH), Poltavska (-5.2 million UAH), Chernihivska (-4.8 million UAH) and Rivnenska (-99 thousand UAH) oblasts had the most significant total losses.
In 2022, car trading companies reported 5.6 billion UAH in net profit, from which they had to pay more than 1 billion UAH in taxes.
If we additionally consider the regional aspect, the share of Kyiv and Kyivska oblast among newly registered cars in 2022 was 28.6%, which is close to the share of registered companies in the regions by quantity - 32.9%. In regions ranking by the number of imported used vehicles, the share of Kyiv and the region was 13.2%, and by the number of domestic resales - 21.8%.
At the same time, the share in revenues was the absolute majority: 54.5%.
Instead, the second region regarding the number of car traders, Volynska oblast (5.8%), was in 10th place in the ranking of new car registrations with a share of 3.7%. However, it ranked second in the ranking of regions by the number of first registrations of "freshly imported" used cars from abroad, with a share of 8.4% of the total. Domestic resales of vehicles are unpopular in this region: Volynska oblast ranked 21st in the rating of registrations, with a share of 2.1%.
At the same time, the region's share of revenues (4.1%) was closer to the rate of new car registrations.
Lvivska oblast, which ranked third in the number of registered car dealerships (3.5%), was the most active in importing used cars (14.3% of all vehicles in 2022). New cars accounted for 6.4% of the total. In the ranking of regions by the number of domestic resales, the region ranked 5th with a share of 7.3%.
However, according to the submitted reports, the share in the income of Lviv car traders was only 3.5%.
Conclusion 2. In Ukraine, out of over 5.3 thousand active companies registered under the NACE codes of sale of cars and light motor vehicles and sale of other motor vehicles, only about 1.3 thousand submitted reports on their activities in 2022. Most of these companies are located in Kyiv and the region and paid the most income taxes in 2022. The rankings of regions by the number of registered auto traders and their share of income do not match the number of vehicle registrations of different types in those regions.
Who officially trades in vehicles?
The analytics prepared by YouControl.Market experts shows that only one microenterprise was among the Top 25 car trading companies by net income in 2022. The remaining 24 companies were large or medium-sized regarding financial reporting requirements.
Ukrainian Armor, LLC, a private enterprise in the defence industry specialising in designing and manufacturing military and civilian equipment, took the first place. Therefore, even though the main NACE code of the organisation is the sale of motor vehicles, it cannot be called a classic auto trader.
Toyota-Ukraine, the official Toyota dealer in Ukraine registered in Kyiv, took second place. Last year, the company received over 10.3 billion UAH in net revenue and almost 1.5 billion UAH in net profit.
The third place was taken by AutoCapital, a Private Joint Stock Company, the official distributor of Mercedes-Benz Group AG in Ukraine, which is part of the UkrAvto Corporation group of companies. The company reported 7.3 billion UAH in net revenue and 670 million UAH in net profit in 2022.
The official dealer of BMW and MINI brands, AWT Bavaria Ukraine, LLC, took the fourth place. The company received 5.1 billion UAH in net revenue and 255 million UAH in net profit last year.
Winner Imports Ukraine Ltd, a limited liability company with foreign investments, is one of the top five dealers of Ford, Volvo, Jaguar, Land Rover, Porsche, Bentley and MG brands. The company reported 5.1 billion UAH of net revenue in 2022 and 255 million UAH of net profit in its financial statements.
All 25 of the largest car dealers in Ukraine were new car sellers. Few organisations are not official importers or dealers of car brands and could trade in used vehicles, even in the Top 100 car dealers. There were only 7 of them, 6 of which are registered in Volynska oblast and mainly import used cars from abroad rather than engage in domestic resales.
Conclusion 3. Most car dealers in the Top 100 in terms of net income in 2022 are official importers or dealers of new cars. The list includes only 7 companies that could potentially trade in used cars, 6 of which are located in Volynska oblast and are likely to import used cars from abroad rather than resell them domestically.
So, who sells used cars?
Every month, Ukrainians post about 240,000 car sales ads online. The Automoto.ua aggregator collects them from 100 car websites in Ukraine. This data makes it possible to estimate the actual sales volumes of used cars, as it is the most objective indicator of the number and structure of vehicles offered on the market.
Based on this data set, experts from the Automotive Market Research Institute determined that 472 car dealers published more than 9 ads during the three months, meaning that they sold an average of at least three cars per month and can be considered active sellers. In total, they published 49,000 ads in three months. On average, this is 16,000 per month.
During the same three months, another 1,653 personal accounts were not identified as car sales companies but posted more than 9 ads and published 41,500 ads. That is, almost 13 thousand per month.
The hypothetical size of a business segment that sells at least three cars per month can be estimated at 90.5 thousand ads published by 2125 accounts – about 30 thousand ads per month, which is 12.5% of the total. On average, one dealer posts 14 sales ads per month.
The most active were business sellers from Kyivska (351 companies, 19.2 thousand ads), Lvivska (115 companies, 6.2 thousand ads), Odeska (116 companies, 6.1 thousand ads), Dnipropetrovska (93 companies, 3.1 thousand ads) and Kharkivska (70 companies, 2.7 thousand ads) oblasts. These trends are consistent with the statistics of registration operations: where there are the most published ads, there are the most car sales. However, they differ from the statistics relating to companies regarding the number of registered legal entities in the regions and their income.
Among the brands selling used cars, Autopark.ua was the most active over the three months (6,000 ads). Boss Auto took the second place (1,826 ads), and AUTOGERMANIA (1,759 ads) was third. AutoPodium (1,654 ads) and Autogalaktika (1,237 ads) were also active.
At the same time, only two organisations included in the ranking of the largest car traders by net income made it to the Top 15 used car sellers on the Internet: VIDI Group and the official Volkswagen dealer, Autohouse Atlant.
Some companies listed above – those that actively trade in the used car market – either do not have a registered legal entity, operate on behalf of another legal entity, or under a different brand name (not always registered under applicable law). Such companies do not appear in the official statistics of active car traders.
Conclusion 4. Every month, used car dealers publish over 30,000 ads on the Internet, which is 12.5% of the total. Regional trends in online sales are consistent with the statistics on registration transactions with cars but differ from the statistics on the number of registered legal entities in the regions and their income. The Top 15 online used car sellers include only two organisations in the ranking of the largest car traders by net income. Some used car dealers either do not have a registered legal entity, operate on behalf of another legal entity, or under a different brand name (not always registered under applicable law).
How much additional tax revenue could the budget receive?
According to the Automotive Market Research Institute, based on Automoto.ua data, Ukrainians offer used cars worth about $2 billion monthly for sale. The average cost of a vehicle in June was $5,550.
Among all online sales ads, about 12.5% are published by car dealers (about 30,000). About 70,000 internal resales of used cars are registered monthly in service centres.
As 32.8% of sales transactions today are trade-in transactions, as they are carried out with the participation of business entities, the actual business segment of used car sales today is at least 40% of the total. In this case, the average monthly number of transactions will be close to the number of ads published by the business: 30,000.
As the average car in Ukraine costs $5,550, the total value of vehicles that auto dealers can potentially sell could be around $166.5 million. Given that the minimum margin of an auto dealer is 2% of the car's value, the monthly profits of used car dealers can be estimated at $3.3 million. The income tax on this share (18% under current law) will amount to almost $600,000 per month or nearly 22 million UAH at the NBU exchange rate.
Conclusion 5: If conditions are created for the legal operation of aftermarket dealers in the legal field, the state budget could receive an additional 260 million UAH annually.
What could be the solution?
The segment of domestic resales of used cars in Ukraine is in the shadows. According to rough estimates by the Automotive Market Research Institute experts, the actual share of transactions carried out by the car business can be up to 40%–50%.
In the EU, used car trading is an entirely legal business, and trade-in services, i.e. exchanging an old car for a newer one, are a convenient and civilised service. The share of business sales of used cars in the German market is almost 80%.
The transformation of the automotive market in Ukraine, which began in 2016, will continue. New networks of car dealerships, new used car dealers, and new companies will be formed. Today's "private sellers" who sell cars unofficially will unite to do so or create small businesses.
Legislative changes are needed to speed up the "legalisation" of this market segment: market participants should be allowed to operate conveniently and without unnecessary bureaucracy. For example, legislative changes in 2016 and 2018 made it possible for used car importers to officially operate and sell used cars, paying tax on margin rather than gross income. That brought the import of used cars to Ukraine out of the shadows, created a new business segment in the market and allowed regular replenishment of the state budget.
For the trade-in service and used car trade to operate as transparently as possible and come out of the shadows completely, it is necessary to remove unnecessary bureaucracy and let those who wish to do so legalise their work and bring order to the industry. That will allow for additional revenues to the state budget.
The solution may be the adoption of draft law #9083. It will allow companies with the appropriate economic activity code (sale of vehicles) and registered with the Main Service Centre of the Ministry of Internal Affairs not to register cars for themselves if they are purchased for resale. They can be accounted for as goods rather than fixed assets of the company. That will reduce the bureaucratic burden on car dealers, optimise the work of the MIA Service Centres, and relieve the Territorial Centres of Recruitment and Social Support of unnecessary workload, which is especially important under martial law. Data exchange on vehicles can be done electronically – this will be faster and more efficient.
In its expert opinion, the Ministry of Finance of Ukraine notes that the implementation of the provisions of the draft law may reduce revenues to the special fund of the state budget and the general fund of local budgets as administrative fees for the issuance of registration certificates and license plates are paid when providing administrative services for the registration and re-registration of cars. However, according to Automotive Market Research Institute experts, this fee currently amounts to UAH 862 for vehicles. Hence, it only covers administrative costs in practice but does not generate actual budget revenues.
If the amendments are adopted, buyers will have more opportunities to protect their rights as consumers, and more than 2,000 car dealers currently operating in the shadows will be able to move into the legal field, conduct sales operations officially, report their profits and pay the relevant taxes. According to Automotive Market Research Institute experts, this will mean over 260 million UAH in additional direct revenues to the state budget from income tax alone. The indirect positive impact of legalising the used car trade will be much more significant.