Corporate income tax for legal entities – single tax payers of the fourth group: answers to the most common questions

Legal entities – single tax payers of the fourth group pay corporate income tax upon receipt of income (profits):

from sales transactions or other alienation of securities;

from the corporate rights issuer, investment certificates or other securities certifying the ownership right of a share (unit) in property (assets) of the issuer, in connection with distribution of part of its income.

Relevant changes are provided for by the Law of Ukraine № 4577.

Income (profits) are calculated according to accounting rules.

Upon the receipt of such income (profits), payers have a right to submit the corporate income tax declaration for the tax (reporting) periods of 2022 and/or 2023, and/or 2024, and/or 2025 by April 6, 2026, and pay the corporate income tax in manner and amounts established by the Tax Code of Ukraine – within 6 months from the date of entry into force of the Law № 4577, which entered into force on 05.10.2025.

The most common questions:

As a legal entity – single tax of payer the fourth group, declare income (profits) from sale or other alienation of securities and income received from the issuer of corporate rights, investment certificates or other securities certifying its ownership right to a share (unit) in property (assets) of the issuer, in connection with distribution of part of its income.

How to reflect such income (profits) and calculate corporate income tax in declarations for 2022-2025 in order to exercise right provided for in Paragraph 14 Sub-section 8 Section XX “Transitional provisions” of the Tax Code of Ukraine.

Legal entity – single tax payer of the fourth group has a right to declare the specified income (profits) and submit corporate income tax declaration for the tax (reporting) periods 2022 and/or 2023, and/or 2024, and/or 2025.

Deadline for submitting such declarations and paying corporate income tax expires on April 6, 2026 (Monday), as the Law № 4577 entered into force on 05.10.2025.

For corporate income tax declaration, it is recommended to use declaration form valid on the date of submission and submit it together with the annual financial reporting for the relevant reporting year.

Preparing the Declaration, it is recommended to reflect relevant indicators and information in the following order:

mark is placed in the line “business entity – legal entity that chose simplified taxation system” in line 10 “Special marks” of the Declaration;

amount of annual income from any activity (net of indirect taxes), determined according to accounting rules. This includes income (profits) from the sale of products (goods, works, services), other operating income, financial income and other income in line 01 of the Declaration according to (Sub-paragraph 134.1.1 Paragraph 134 Article 34 of the Tax Code of Ukraine);

amount of income received from the issuer of corporate rights, investment certificates or other securities certifying ownership right to a share (unit) in property (assets) of the issuer, in connection with distribution of part of its profit, calculated according to accounting rules in line 02 of the Declaration;

amount of income (profits) from sale or other disposal of securities, calculated according to accounting rules in line 03 Calculation of tax differences of the Declaration.

In addition, to determine this indicator, payers must prepare and submit as part of the Declaration:

Annex Calculation of tax differences to line 03 Calculation of tax differences of the Declaration (hereinafter – Annex Calculation of tax differences);

Annex Securities to lines 4.1.3 Securities, 4.1.4 Securities of Annex Calculation of tax differences to line 03 Calculation of tax differences of the Declaration (hereinafter – Annex Securities);

taxation object is indicated in line 04 of the Declaration, which is equal to the sum of the indicators of lines 02 and 03 of Calculation of tax differences of the Declaration; 

amount of income tax is determined in line 06 of the Declaration (indicator of line 04 of the Declaration x 18 (basic tax rate) / 100

line 17 of the Declaration indicates income tax for the reporting (tax) period (year);

line 19 of the Declaration indicates accrued income tax equal to the figure in line 17 of the Declaration.

In the table “Presence of annexes¹³” of the Declaration, marks “+” are placed in the corresponding cells “Calculation of tax differences”, “Securities”, “Financial reporting¹⁵” regarding submission of Annex Calculation of tax differences, Annex Securities and Financial reporting prepared according to national accounting regulations (standards) (mark National accounting regulation (standard) is placed) or international financial reporting standards (mark “IFRS” is placed) as a part of the Declaration.

In the table "Availability of attachments submitted to the Corporate income tax declaration - financial reporting forms¹⁵" of the Declaration, marks "+"are placed in the corresponding cells for the financial reporting forms submitted together with the Declaration for relevant reporting year.

In the table "Presence of attachments¹⁸" of the Declaration, mark is placed on the provision of attachment, in which the payer explains discrepancy between the indicator specified in line 02 of the Declaration regarding amount of income received from the issuer of corporate rights, investment certificates or other securities certifying ownership right to a share (unit) in property (assets) of the issuer, in connection with distribution of part of its income, and the indicator of financial result before taxation (profit or loss) determined in financial reporting.

Regarding the preparation of Annexes Calculation of tax differences and Securities to the Declaration

Annex Securities has to be compiled by the single tax payers of the fourth group – legal entities in order to reflect income (profits) from sale or other alienation of securities, indicating relevant indicators:

line 01 of Annex Securities reflects income from the sale and other methods of disposal of securities, with a breakdown of such income by type of securities in lines 01.1 – 01.11 of Annex Securities;  

line 02 of Annex Securities reflects expenses related to the acquisition of securities, and a breakdown by type of securities is provided in lines 02.1 – 02.11 of Annex Securities;

line 4.1.4 Calculation of tax differences of Annex Securities indicates financial result from the sale and other methods of alienation of securities (positive value is indicated (line 01 – line 02)). The indicator of line 4.1.4 Calculation of tax differences of Annex Securities is transferred to line 4.1.4 Securities of Annex Calculation of tax differences.

Herewith, lines 01.12 Transfer pricing, 01.13, 02.12 Transfer pricing, 02.13, 03, 4.1.3 Calculation of tax differences, 4.1.3.1, 4.1.3.2, 04 of Annex Calculation of tax differences are not filled in.

Annex Calculation of tax differences is ​​compiled in order to transfer to line 03 Calculation of tax differences of the Declaration the indicator on income (profits) received from sale or other disposal of securities, namely:

in line 4.1.4 Securities of Annex Calculation of tax differences, financial result from the sale and other methods of disposal of securities is indicated, which is equal to the indicator of line 4.1.4 Calculation of tax differences of Annex Securities;

in lines 01 and 03 of Annex Calculation of tax differences, amount equal to the indicator of line 4.1.4 Securities of Annex Calculation of tax differences is also indicated.

Meaning of line 03 of Annex Calculation of tax differences Appendix is ​​transferred to line 03 Calculation of tax differences of the Declaration.

How the single tax payer of the fourth group – legal entity can declare income (profits) for:

sale or other disposal of securities,

received corporate rights, investment certificates or other securities certifying ownership right to a share (share) in the property (assets) of the issuer in connection with distribution of part of its income,

if such a payer submitted declarations for 2022-2025 and declared corporate income tax upon payment of income (profits) to a non-resident with a source of origin from Ukraine or upon receipt of adjusted profit of a controlled foreign company?

If declarations have already been submitted for such tax (reporting) periods, the payer may:

-- submit clarifying declarations for the tax (reporting) periods 2022 – 2025;

-- reflect in these clarifying declarations:

- previously declared indicators,

- income (profits) from the sale or other alienation of securities and income received from the issuer of corporate rights, investment certificates or other securities certifying ownership right to a share (unit) in property (assets) of the issuer in connection with distribution of part of its income.

Submission of clarifying declarations does not entail accrual and payment of fines or penalties provided for by the Tax Code.

The clarifying declarations must be accompanied by:

- all annexes to relevant lines of the declaration,

- annual financial reporting,

- additions with explanation of the declared indicators regarding amounts of the corporate income tax liability, determined and declared according to Paragraph 14 Sub-section 8 Section XX of the Tax Code of Ukraine.

For reference:

TCU – Tax Code of Ukraine;

Law № 4577 – Law of Ukraine № 4577-IХ as of 21.08.2025 “On amendments to the Tax Code of Ukraine and other Laws of Ukraine regarding support for enterprises of the defense industrial complex”;

Declaration – Corporate income tax declaration, form of which was approved by Order of the Ministry of Finance of Ukraine № 897 as of 20.10.2015, registered in the Ministry of Justice of Ukraine on 11.11.2015 under № 1415/27860 (as amended by Order of the Ministry of Finance of Ukraine № 101 as of 20.02.2023) with changes.