Ukraine

Changes related to the introduction of martial law

Several changes became effective from 1 January 2022 related to the following areas:

• Introduction of limitations related to tax loss carryforwards for large taxpayers.
• Introduction of minimal tax burden for agricultural producers on land plots.
• introduction of the controlled foreign company (CFC) concept (see Controlled foreign companies (CFCs) in the Group taxation section).
• Place of effective management of non-resident companies in Ukraine (see the Corporate residence section).
• Introduction of value-added tax (VAT) for digital business-to-consumer (B2C) services supplied by non-residents.

On 14 December 2021, the Ukrainian Parliament adopted The Law of Ukraine "On Amendments to the Tax Code of Ukraine to Stimulate the Digital Economy in Ukraine", which is a tax part of the “Diia City” special legal regime and provides special tax conditions for residents of the City. The law entered into force on 1 January 2022.

On 1 August 2025 a new double tax treaty with Japan has entered into force .

Also, on 19 August 2022, Ukrainian tax authorities acceded to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information. Thereby Ukraine joined the international framework for automatic exchange of tax-related information on financial accounts of taxpayers under the rules on the Common Standard on Reporting and Due Diligence for Financial Account Information (CRS) in 2022. Since that time Ukraine performed two rounds of information exchange (in 2024 and 2025).

In 2025 Ukraine announced joining the Multilateral Competent Authority Agreement on Automatic Exchange of Information on Income Derived through Digital Platforms. Respective Draft Law ‘On Amendments to the Tax Code of Ukraine and the Law of Ukraine “On Banks and Banking Activity” regarding the implementation of the international automatic exchange of information on income received through digital platforms’ No. 14025 is pending hearing by the Parliament.

“Defence City” tax regime

On 5 October 5 2025, the Law of Ukraine dated 21 August 2025 No. 4577-IX "On Amendments to the Tax Code of Ukraine and Other Laws of Ukraine on Supporting Enterprises of the Defence-Industrial Complex" entered into force, introducing new special tax regime “Defence City” aimed to support defence-related business. Defence City residents can benefit from specific conditional exemptions from CIT, land tax, real estate tax and ecological tax. That regime is supposed to stay in force until 2036 or accession of Ukraine to the EU, whichever happens earlier.

Diia City: Special legal and tax regime for IT companies in Ukraine

Starting from 2021 the 'Diia City' (a special legal and tax regime for IT companies in Ukraine) started working. This regime is created for the purpose of stimulating the development of the IT sector in Ukraine. Benefits of 'Diia City' include:

• Certain guarantees for its residents (in particular, the validity of the legal regime for not less than 25 years, the stability of tax conditions, the presumption of legality of the residents of 'Diia City').
• The possibility of choosing a special tax regime.
• Protection from excessive interference in the resident’s activities by the state.
• Simplification of the registration of relations with IT specialists (possibility of hiring employees within labour relations, individuals, including foreign IT specialists, under gig contracts, and concluding agreements with private entrepreneurs).
• Engaging and encouraging talent in the field of IT by establishing additional compensation, social guarantees, the use of options, etc.

Increased corporate income tax (CIT) rate for banks and financial institutions 

The CIT rate for the banks' and financial institutions’ profits has been increased since the beginning of the full-scale Russian invasion of Ukraine. In particular, the following rules apply:

• Temporarily, based on the results of the tax years 2023 and 2024 the corporate income tax rate is 50%for the banks, including in case of the advanced CIT payments;

• The banks cannot utilise their tax losses carried forward from the past periods in 2023 and 2024. Currently, this limitation applies to 2023 and 2024 reporting periods only and tax losses carried forward could be utilised in the tax periods starting from 1 January 2025;

• Starting from 1 January 2025 the CIT rate for financial institutions (excluding insurance companies) is increased to 25 percent (instead of the general 18 percent rate);

• It is planned that, starting from 1 January 2026, the CIT rate for banks will amount to 50%. The banks will not be able to use their tax losses carried forward from previous periods in 2026. Tax losses carried forward can be used in tax periods starting on 1 January 2027 (this draft law Draft Law “on Amendments to the Tax Code of Ukraine Regarding the Special Provisions for Taxation of Banks with Corporate Income Tax in 2026” N14097 is pending the President’s signature).

Advance CIT payments to be paid by fuel trade retailers

Starting from December 2024, fuel trade retailers are obliged to pay advance CIT payments for each place of retail fuel trade included in the Unified Register of Licensees and Places of Circulation. Advance CIT payments are to be made on a monthly basis not later than the 20th day of the reporting month.

The following amounts of the advance CIT payment are prescribed (per each place of retail fuel trade):

• For locations selling only liquefied gas: 30,000 Ukrainian hryvnias (UAH).
• For locations where the volume of liquefied gas sales exceeds 50% of the total fuel brought to a temperature of 15°C in total volume of fuel sold in the previous month: UAH 45,000.
• For other places of retail fuel trade: UAH 60,000.

The amount of CIT advance payments paid during the reporting (tax) period reduces the overall CIT liabilities of the taxpayer for such reporting (tax) period defined at the general CIT rate of 18%, in the amount that does not exceed the amount of the accrued CIT liability for such tax (reporting) period. 

The amount of the advance CIT payments that exceeds the overall CIT liability:

• cannot be carried over to future periods
• is non-refundable, and
• cannot be credited against other taxes and fees.

In case of non-payment/late payments of the advance CIT payments, the fuel trade retailer is subject to liability in accordance with current Ukrainian tax legislation, with the application of financial penalties.