Most residents of the «Diya.City» tax regime choose to pay twice the income tax, instead of the 9% capital gains tax (PnVK). What is the reason?
Most residents of the «Diya.City» tax regime choose to pay twice the income tax, instead of the 9% capital gains tax (PnVK). What is the reason?
Forbes Ukraine reports that in 2025, the share of companies in Diia.City paying PnVK decreased by 8%, to 39%. Last year, 83 companies refused it.
The Chairman of the Finance Committee of the Verkhovna Rada, Danylo Hetmantsev, previously noted that as of October 1, 2025, there were 2,721 companies in the «Diya.City» register, of which 1,046 had switched to paying tax on withdrawn capital. In his opinion, the dynamics of companies’ transition to PnVK indicates the need for further improvement of tax incentives.
«Business recognized the regular income tax as a more rational choice than the PnVK,» says Hetmantsev.
Currently, there are almost 3,400 IT companies residing in Diia.City. Upon joining, companies can choose to pay 9% PnVK or twice the percentage of income tax. PnVK is paid only on transactions that are considered as capital withdrawals from the company, such as: dividends, insurance payments, financial assistance, royalties.
An anonymous tax director of one of the Ukrainian IT companies told Forbes Ukraine that what makes PnVK unattractive is that many payments can be equated to dividends.
«When a new form of tax is introduced that provides benefits, tax officials monitor those who use it more closely. Companies do not want unnecessary attention to themselves,» commented Vitaliy Horovyi, founder of the InSoft.Partners investment holding.
The press service of the IT company Ciklum, which is part of «Diya.City», explained the choice in favor of the classic tax by the fact that the practice of applying the PnVK is not yet established. Ciklum believes that the ambiguous interpretation of the norms by the tax authority creates additional risks.
Another reason companies refuse to pay PnVK is that the law does not take into account the specifics of Ukrainian IT. According to Igor Yasko, managing partner of the law firm Winner, the tax authority qualifies receivables over 365 days as a withdrawal of capital and requires paying PnVK from this amount.
At the same time, Ukrainian IT companies often face payment delays from foreign clients of 13-14 months. Yasko points out that this is a common phenomenon when working with large corporations or government contracts.
