International taxation: revenues from self-adjustment of tax liabilities increased by more than 40%

Revenues from self-adjustment of tax liabilities in areas of international taxation, transfer pricing and controlled foreign companies increased by more than 40 % in the first 9 months of 2025.

Taxpayers independently adjusted the corporate income taxation object for about 5 billion UAH, which is at the same level as last year. At the same time, amount of paid tax on it increased by 20% – from 0.5 billion UAH in 2024 to 0.6 billion UAH in 2025. As a result of control and verification measures, 84.9 million UAH was received by the budget.

Volume of self-adjustment of the income tax of non-residents with a source of origin in Ukraine has almost doubled – from 69.5 million UAH to 154.9 million UAH. According to results of control and verification measures, 466.5 million UAH was paid to the budget. 

In the reporting period, controlling entities of controlled foreign companies independently adjusted and paid 70 million UAH to the budget, which is 15 times more than in 2024 (4.6 million UAH).

Important factor in increasing efficiency of work was active exchange of tax information with foreign competent authorities. Established cooperation – prompt correspondence, reconciliations and online meetings allowed to significantly reduce the time for obtaining information and improve its quality.

Due to this, it was possible to identify abuse risks in terms of international agreements, overestimation of non-residents’ profitability and underestimation of the taxation object by billions UAH. Responses received to 90% of international inquiries became basis for the in-depth analysis and formation of evidence base in complex tax cases.

Systematic analytical work, interagency interaction and sectoral approach ensure not only financial results, but also form new standards of transparency of business processes.

International taxation in Ukraine is becoming a partnership instrument, trust and shared responsibility between the state and business, reflecting the country’s desire to act according to the best global practices.