Ukrainian law does not allow a company to hold resident status in both Defense City and Diia City at the same time. The restriction is not technical, but structural: each regime is built around a different policy objective and tax architecture, and the legislator treats them as alternative tracks rather than cumulative benefits.
For defense industry firms, Defense City offers a package of tax, customs, and regulatory preferences intended to accelerate domestic production capacity under security pressure. At the same time, access to the core corporate income tax relief is tied to strict conditions, including reinvestment obligations and limits on dividend distribution. One of those conditions is explicit non residency in Diia City.
Practical consequences for corporate planning
- Companies must choose one special regime model based on business profile.
- Attempting to combine both statuses blocks access to expected tax relief.
- Investment and dividend policies must be aligned with chosen regime rules.
- Legal structuring and compliance controls become critical before application.
For technology groups with both civilian and defense related activities, the decision may require deeper corporate segmentation. Management teams need to compare long term tax effects, compliance burden, financing plans, and growth trajectory under each regime. Choosing the wrong framework can create costly restructuring later.
The key message for business is strategic clarity: special regimes are not additive perks, but policy instruments with mutually exclusive eligibility logic. Early legal and tax modeling is therefore essential before committing to residency applications.
