Page 54 - CEE Tax Guide 2025

Ukraine

Forvis Mazars LLC
15A Kyrylivska Street, Kyiv,
04080, Ukraine
Phone: +38 044 390 71 07
www.forvismazars.com/ua

Corporate taxes and other direct taxes Companies with annual income below UAH
40 million (approx. EUR 917K) are entitled not
The standard CIT rate of 18% applies to the to apply any tax adjustments (except for tax losses
worldwide income of resident companies. The CIT carried forward).
rate for banks and financial organisations: 25%.
Non-resident companies and their permanent A 15% withholding tax (WHT) is imposed on passive
establishments (PE) pay CIT on income received income paid to non-residents.
from Ukrainian sources. Payment for services is WHT-exempt. WHT is also
Taxable profit is calculated as financial profit before levied on other payments to non-residents, e.g.
tax, adjusted with certain tax adjustments. constructive dividends, alienation of shares
Thin capitalization rules apply to loans granted in Ukrainian asset-rich companies, freight, etc.
by any non-resident (the debt-to-equity ratio A lower WHT rate or exemption may apply under
is 3.5), with exceptions for certain financial and a double tax treaty (DTT). Ukraine has a wide DTT
leasing entities. network (more than 70). A “look-through approach”
Tax losses can be carried forward indefinitely with is available. The application of DTT benefits
limitations for large taxpayers. Loss carry back is restricted by a “principal purpose test”.
is not permitted.
Transfer pricing (TP) rules apply to controlled
Transfer pricing in Ukraine transactions (CT) with related non-residents and
with non-related foreign companies registered
Arm’s length principle Since 2013
in low-tax jurisdictions or not paying income tax.
Documentation liability Since 2013 TP rules apply if the company’s annual revenue
APA Applicable exceeds UAH 150 million (approx. EUR 3.4 million),
to large taxpayers, and its CT with the same counterparty exceed
no cases in practice.
UAH 10 million (approx. EUR 229K). Transactions
Country-by-Country For MNE with income ≥ between non-resident and its PE fall under
liability EUR 750 million
(+ other conditions). TP control if the amount exceeds UAH 10 million.

Master file-local file For MNE with income ≥ Undistributed profits of controlled foreign
(OECD BEPS EUR 50 million. companies are taxed at 18% at the level of Ukrainian
13) applicable
company or individual (subject to exemptions).
Penalty Non-residents operating in Ukraine through
lack of documentation 3% of the value PE should register with the tax authorities and file
of controlled transactions, their CPT returns.
max – UAH 605,600
(approx. EUR 14K). Sole traders, companies with annual income
below UAH 8.3 million (approx. EUR 190K), and
tax shortage 25% of tax underpayment;
50% in case agricultural producers may apply for the simplified
of recurrent violation taxation system.
within 1,095 days.
Related parties 25% Direct/indirect VAT and other indirect taxes
and or common control.
more As a non-EU member, Ukraine has not implemented
Safe harbors No – EU VAT Directives.
The standard VAT rate is 20% (14% for the import
Level of attention paid 7/10
by Tax Authority of some agricultural products; 7% for the supply

Central and Eastern European tax guide 2025 Forvis Mazars 54