The answer to this question is given by the head of Horodotsk DPI Roman Myskiv.
In accordance with clause 19 of subsection 94 of chapter XX of the Tax Code of Ukraine (hereinafter – the Code), state guarantees and exemptions from liability, provided for by subsection 94 of chapter XX of the Code, do not apply to assets obtained as a result of criminal offenses, except for criminal offenses provided for in articles 212, 212¹ (regarding the payment of taxes as an individual or an individual entrepreneur), Art. 366 (regarding tax and/or financial reporting documents, customs declarations, tax invoices, primary documents, other reporting on taxes, fees, mandatory payments), Art. 367 (if the crime is related to the violation of the requirements of tax, customs, currency and other legislation, the control of compliance of which is entrusted to the controlling bodies) of the Criminal Code of Ukraine.
State guarantees and exemptions from liability provided for in this subsection also do not apply to:
assets of a natural or legal entity, the acquisition of which contains signs of a criminal offense provided for in Art. 3685 of the Criminal Code of Ukraine, and/or which are subject to recovery as unfounded in accordance with the procedure established by Chapter 12 of Section III of the Civil Procedure Code of Ukraine;
currency values, rights of claim and money lent to third parties, reflected in a one-time (special) voluntary declaration, in the event of a violation by the declarant of the conditions established by clauses 8 and 9 of subsection 94 of section XX of the Code of Conditions by the central executive body implementing the state tax policy placement of currency values in banking or other financial institutions, absence of a loan agreement between the declarant and a legal entity and/or notarized certificate of a loan agreement between the declarant and another natural person, absence of a corresponding document confirming the right of claim.