Taxation income tax peculiarities in 2026: the most frequently asked questions

In 2026, a new basic corporate income tax rate of 50% was introduced for banks. This is provided for by the Law of Ukraine №I X 4698 as of 03.12.2025, which amended the Tax Code of Ukraine and determined peculiarities of banks’ taxation.

The increased rate will apply to:

- income taxation, starting from the tax reporting periods of 2026;

- taxation of dividends according to Paragraph 57.1-1 o Article 57 of the Tax Code of Ukraine.

In 2026, the banks cannot reduce their financial result before taxation by the amount of losses from previous years.

Restriction will be in effect throughout 2026. Amounts of the negative value of taxable object (including those that arise in 2026) may be taken into account determining financial result starting from the reporting periods of 2027.

The most common questions:

What rate is used for declaring income tax for 2025?

The rate remains unchanged at 25%.

What rate should be used when paying dividends by the bank for 2024, which were made in 2025 and 2026?

- Payment in 2025 (regardless of the period for which they are paid) - rate 25% (current rate in 2025).

- Payment in 2026 - rate is 50%.

In 2026, when paying dividends based on the results of 2025, the bank plans to apply the right to reduce the amount of dividends paid by the amount of the corporate income tax object for this reporting year, which is determined at a rate of 25 percent. Does the bank have the right to such a set-off if all requirements are met (the declaration has been filed and the tax liability has been paid in full), and what rate is applied to tax the amount of the excess of dividends over the value of the taxable object?

Paying dividends in 2026 based on the results of 2025, the bank plans to apply right to reduce amount of dividends paid by amount of the corporate income taxation object for this reporting year, which is determined at the 25%rate. Does the bank have a right to such a set-off if all requirements are met (declaration has been submitted and tax liability has been paid in full), and what rate is applied to tax the amount of the excess of dividends over the taxation object’s value?

The bank has the right to such a set-off in compliance with the procedure specified in Article 57.1-1 of the Tax Code of Ukraine. A tax rate of 50 percent is applied to the amount of the excess.

Is it correct to state that banks do not reduce the financial result before taxation by the amount of the negative value of the object of taxation of previous tax (reporting) years only in the reporting periods of 2026 (first quarter, half-year, nine months, year).

Yes.

For reference:

Law of Ukraine № 4698 as of 03.12.2025 “On Amendments to the Tax Code of Ukraine and other Laws of Ukraine regarding taxation peculiarities of banks with the corporate income tax in 2026 and postponement of deadlines for implementation of the electronic system for circulation of alcoholic beverages, tobacco products and liquids used in the electronic cigarettes”