The National Bank on May 21 announced its official position on bill №14097 — a document that sets a 50% corporate income tax rate for banks in 2026. The regulator opposed it. The paradox is that the NBU itself supported this same rate in 2023 as a "one-time exceptional measure."

How an exception became the norm

The 50% corporate income tax for banks was first introduced in late 2023 — it covered the entire year retroactively. In 2024, the Rada repeated the scheme. By then, the NBU already opposed it, but the law was adopted. In 2025, the rate returned to the baseline 25%. However, Danilo Hetmantsev, chair of the Rada's financial committee, registered bill №14097, which again proposes 50% — this time for 2026, and with an additional ban on accounting for losses from previous years when calculating the tax base.

On December 3, 2025, the Rada adopted the bill in full — 272 deputies voted for it. The President signed the law on December 24.

"We supported the introduction of an extraordinary tax on bank profits in 2023 as a one-time exceptional measure. Now we consider this initiative dangerous altogether."

NBU Governor Andriy Pyshnyy

What the NBU considers real risks

The regulator points to three specific threats. First, liquidity: tax payments require a significant outflow of funds from banks simultaneously. Second, capitalization: according to the NBU's estimates, at least 8 banks, including 2 state-owned ones, may fail to meet recapitalization programs based on the results of 2025 stress tests — and then the state will compensate for the capital shortfall at the expense of taxpayers. Third, lending: banks' loan portfolio just exceeded 1 trillion hryvnias and has been growing for three consecutive quarters — increased taxation will slow this dynamic precisely when business is recovering from the 2022–2023 shock.

The NBU estimates the expected fiscal effect at approximately ~20 billion hryvnias — against the 30 billion declared by the law's authors. The reason: the lion's share of profits is generated by state banks, which already transfer funds to the budget annually in the form of dividends. In other words, part of the "new" revenues is simply moving money from one state pocket to another.

Hetmantsev's argument

Danilo Hetmantsev, chair of the financial committee, did not hide the logic: banks earned record 119.4 billion hryvnias in net profit over three quarters of 2025, while the budget desperately needs funds for defense. According to him, the increased rate will help cover part of the deficit. Furthermore, banks have already "become accustomed" to such taxation levels in 2023–2024 and survived it without visible turmoil.

"In practice, they have already paid the increased tax at the 50% rate twice — they effectively provide one-third of all taxes paid to the budget, or 15 times more than their share of GDP."

Andriy Pyshnyy — on the cumulative burden on the sector

Where the logic of a "one-time measure" cracks

The NBU's main complaint is not fiscal but systemic. As the regulator notes, an exception applied three times ceases to be an exception. The Constitutional Court in its ruling №3-р(II)/2025 of January 21, 2025 confirmed: the legislature must find a balance between frequent changes to the rules and predictability of norms for taxpayers. The ban on accounting for losses from previous years additionally violates the principle of tax equality — ordinary businesses do not have such restrictions.

Business associations supported the NBU: the European Business Association called on the Rada to reject the bill, noting that 8 banks will not be able to fulfill recapitalization programs if it is adopted.

The law has been signed. The 50% rate is effective from January 1, 2026. If in 2026 even one state bank requires recapitalization from the budget — this will mean that the fiscal gain from the increased tax will partially return in the form of state injections, and Hetmantsev's entire arithmetic will collapse.