Ukraine raises corporate income tax rate for banks and postpones introduction of electronic excise stamps

On 25 December 2025, Law of Ukraine “On Amendments to the Tax Code of Ukraine Regarding the Specifics of Taxing Banks with Corporate Income Tax in 2026 and the Postponement of the Effective Date of the Electronic System for the Circulation of Alcoholic Beverages, Tobacco Products, and Liquids Used in Electronic Cigarettes” No. 4698-IX, dated 3 December 2025 (“Law”), was officially published.

The Law provides for a significant increase in the corporate income tax rate applicable to banks, raising the rate from 25% to 50% for 2026. The same 50% rate will apply to the advance corporate income tax payable by banks in connection with dividend distributions in 2026. In addition, the Law prohibits banks from reducing their financial result in 2026 by carried-forward losses from previous years. Such losses may again be used to reduce the financial result before tax starting from 2027.

Furthermore, the launch of the electronic excise system (e-excise) has been postponed from 1 January 2026 to 1 November 2026. Other milestones related to the implementation of the e-excise system have likewise been deferred by 10 months. Accordingly, the marking of goods with paper excise tax stamps will continue until 1 November 2026, while the circulation of goods marked with paper excise stamps will be permitted until 1 May 2028.

The Law also introduces a number of additional changes, including the following:

• Suppliers of defence goods are exempt from accruing compensatory VAT liabilities for supplies made outside state defence procurement contracts.
• VAT exemptions on imports in the energy sector are extended until 1 January 2029.
• VAT exemptions on imports of defence-related equipment (including UAVs, thermal imaging cameras, anti-drone rifles, and similar equipment) remain in effect until 1 January 2027.
• The rules governing the High Tax Trust Territory (“White Business Club”) have been clarified. In particular, generation of profit in the most recent reporting period is now a mandatory eligibility criterion. At the same time, violations related to the submission of tax reporting documents will no longer automatically result in exclusion from the White Business Club. Instead, eligibility will depend on the amount of penalties assessed (excluding penalties under appeal).

Most provisions of the Law entered into force on 26 December 2025, while certain provisions will enter into force on 1 January 2026.

Additional notes

For further information on how these changes may affect your business, operations, or tax position, please contact partner Vadim Medvedev.