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Taxes for IT companies in Diia.City

author
Finevolution
03.04.2025

An innovation of 2021 in the IT sector was the adoption of the Law of Ukraine “On Stimulating the Development of the Digital Economy”, which launched a unique legal framework — Diia.City. Its main goal is to create a comfortable environment for the development of IT business in Ukraine: from programming to game development, tech consulting, and other digital services.

Several years have passed since then, and we can see: the topic still raises many questions. In this article, we not only explain what it is but also share our experience and answers to the most frequently asked questions from entrepreneurs. In short — yes, Diia.City is still functioning, and yes, it may be beneficial in 2025. But let’s take it step by step.

Taxation for companies in Diia.City: what to choose in 2025?

First of all, two important things:

  • The Diia.City regime is voluntary. You are not obliged to join if you don’t see the benefit.
  • If you do join, you get to choose — the classic corporate income tax (18%) or the distributed profit tax (9%).
What’s the difference?
  • If you regularly pay dividends, it’s more profitable for the investor to choose the distributed profit tax (DPT) — 9%.
  • If your company reinvests profits — DPT allows you to completely avoid taxation on those funds.

You can choose the DPT by submitting an application to the controlling authority — no later than 15 days before the start of a new quarter.
If you do not submit the application, the default 18% rate will automatically apply.

What is the distributed profit tax?

This is a tax paid only when the company “distributes” profits out of the business — for example, when paying dividends, interest, royalties, aid, etc. If the funds remain in circulation — no tax is applied.

Which transactions are subject to DPT (9%)?
  • Payment of income from joint activities to Diia.City residents who are not subject to DPT
  • Payment of dividends
  • Payment of royalties
  • Transactions involving the free transfer of assets, services, or financial aid to non-residents of the regime
  • Payment of interest, commissions, compensations, penalties, fines for attracting funds

 For example, if an investor does not withdraw dividends but reinvests them into the Ukrainian business — no tax will be applied.

Who can вecome a Diia.City Resident?

To become a participant in the Diia.City regime, it takes more than just the desire — you must meet the legal requirements.

As of 2025, these requirements are as follows:
  • The company must engage in one of the permitted activities defined by the Law (software development, IT consulting, game development, EdTech, etc.).
  • It must have at least 9 employees or gig contractors, each receiving no less than €1,200 per month.
  • Qualified income (i.e. income from IT activities) must make up at least 90% of the company’s total revenue.
  • The company must not have any negative conditions that would block entry (e.g., bankruptcy, liquidation, sanctions, or non-profit status).

What If I’m a Startup and Don’t Have 9 People Yet?

The law provides for a “transitional” status for startups — with relaxed entry requirements. There is also a separate category for R&D companies (Research & Development) engaged in developing or improving technologies, which may enter Diia.City under simplified conditions.

Interested in development, scaling, or just want to understand why Diya.City is “yours”?

We are ready to help

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What about working with Sole Proprietors (FOPs)?

Many ask whether it’s still possible to work with individual entrepreneurs (FOPs).

As of 2025, Diia.City does allow cooperation with both gig contractors and FOPs. However, if FOP-based cooperation dominates, this may trigger audits. To reduce risks, businesses more often choose gig contract models. And yes — Finevolution helps with legal setup and tax planning for gig contracts.

How does accounting and reporting change after joining Diia.City?

Once you obtain Diia.City resident status, your general tax obligations remain:
You still need to maintain accounting records, file financial reports, and report under either the Distributed Profit Tax (DPT) or Corporate Income Tax — depending on your chosen model.

From a technical standpoint, Diia.City does not introduce separate “regime-specific” reports — however, tax authorities may monitor compliance with residency criteria, such as income structure and staff count.

What if I’m already on the general tax system — can I switch?

Yes, switching is possible at any time (if your company meets the criteria). You need to submit an application to join Diia.City, along with a separate statement if you choose the DPT model.
The new tax model applies starting from the quarter following the application date.

Also, the regime does not bind you permanently. If desired, a company can submit a request to exit the registry. In this case, from the next quarter onward, you return to the general tax system (retaining all rights and obligations as a standard corporate taxpayer).

Is this regime safe during martial law?

Yes, Diia.City continues to function.
As of 2025, there are no official initiatives to cancel or restrict the regime. The government still positions it as a showcase for foreign investors and digital businesses.

However, it’s important that companies report in line with new realities — including Controlled Foreign Companies (CFC) rules, financial reporting, and international structuring.
Professional support is essential here.

What’s better in 2025 — staying as an FOP or joining Diia.City?

If you’re working solo as a Group 3 FOP, this is still a cost-effective model.
But if you’re planning to scale, attract investors, or work with foreign clients — Diia.City offers more credibility and protection.

For example, Western partners increasingly ask: “Are you in Diia.City?” — as it signals legality, transparency, and international compliance.

The Diia.City legal regime is not a ‘magic pill’, but a tool. It works when it fits your goals and your business model. At Finevolution, we consult entrepreneurs every day and craft tailored solutions: we assist with registration, tax model selection, gig contracts, and international structuring.


Our team will be happy to provide advice on the Diia.City. We are available Monday to Friday from 9:00 AM to 7:00 PM. To receive a consultation, send your request through the form below, or message us on Telegram, Viber, or WhatsApp.