With this appeal, the Association of Representatives of International Pharmaceutical Manufacturers AIPM Ukraine (hereinafter – the Association) expresses the position of its member companies regarding the latest initiatives of the National Bank of Ukraine regarding the regulation of currency transactions.

During the last year, the pharmaceutical market, along with other markets, faced serious internal and external economic problems, the occurrence of which is objectively determined by such factors as the deterioration of the state economy in general, a jump in the exchange rate, the unpredictability of the business environment in the conditions of actual martial law, etc. Against the background of such a situation, the introduction of value added tax (VAT) on medicinal products became a separate test for market participants .

Since the pharmaceutical market as a tool of the health care system performs an important social function of providing the population with medicines, the result of all these factors was that pharmaceutical manufacturers were forced to become the object of negative attention from the public and the authorities. At the same time, it is worth noting that despite all these challenges, foreign pharmaceutical manufacturers operating in Ukraine continued to carry out their important work without stopping the supply of medicines to the country. Taking on all the risks and losses, foreign drug manufacturers tried in every possible way to restrain the increase in prices and provide Ukrainian citizens with the opportunity to receive the necessary medical supplies.

For its part, the Government is trying to ensure price stabilization by introducing a procedure for referencing the prices of medicinal products, as well as by regulating currency transactions.

In the context of the latter, on September 22, 2014, the National Bank of Ukraine published  Resolution of the National Bank of Ukraine No. 591 On Amendments to Certain Regulatory Acts of the National Bank of Ukraine (hereinafter referred to as the Resolution). The provisions of this Resolution have become mandatory for all subjects of economic activity, including the pharmaceutical market.

Having analyzed the document, the Association is forced to express its reservations regarding the following provisions of the Resolution.