Analytics instead of formal control: results of 2025 in the international taxation sphere

6.3 billion UAH of additional financial result before taxation, almost 20% growth in income tax, +365.3 million UAH of revenues and 3.8 billion UAH of the court decisions won. These are the key results of 2025 in the international taxation and transfer pricing spheres.

"Last year, tax control finally began to change its focus: fewer formal audits - more analysis, predictability and responsibility. We make all decisions based on data, risks and the real economy" – this was informed by acting Head of the State Tax Service Lesya Karnaukh on the Facebook page.

In this area, risk-based approach, digitalization and minimization of the human factor remain the key. Control does not begin only with the fact of existence of controlled operations - first analysis, risk indicators and work with data.

Results of 2025:

- 472 taxpayers submitted 582 clarifying income tax declarations,

- financial result before tax increased by 6.3 billion UAH,

- amount of income tax based on the results of independent adjustments increased by almost 20% compared to the previous year.

It is this approach that reduces administrative burden on honest business and creates predictable rules of work.

International Taxation: From Control to Compliance

At the end of the year:

- independent adjustments of tax liabilities on non-residents' income increased by 2.9 times;

- revenues from control and verification measures increased by 3.3 times - by 365.3 million UAH.

Separate emphasis is on judicial practice.

In 2025, principled court decisions were received in favor of the tax authority for the amount of almost 3.8 billion UAH, which shape the further practice of applying international conventions.

Controlled foreign companies:

Despite the war and complex residency questions, the controlled foreign companies’ sector shows steady growth in voluntary declarations:

-  number of declared controlled foreign companies increased by 26%;

-  number of controllers of controlled foreign companies – by 17%.

2025 is used as a compliance period without penalty pressure – through clarification, training, analytics and cooperation with payers.

Result:

- revenues from self-adjustment by the of controllers of controlled foreign companies – 87.1 million UAH (for comparison: 4.5 million UAH in the previous year).

“Almost 80% of this result was achieved due to information obtained within the framework of the international exchange with competent authorities of other states. A targeted, legally balanced and internationally coordinated approach is effective. In cases where voluntary compliance and explanatory work do not yield results, control and verification function is applied” – Lesya Karnaukh added.

Control is spot-on, reasoned, and based solely on risks and analytics.

In 2025, about 700 documentary audits were conducted on international taxation and regarding the controlled foreign companies’ questions. This allowed to provide additional revenues to the budget and restore taxation fairness.