Comprehensive Business Relocation for Ukrainian Companies

In the autumn of 2022, queues at Polish notary offices for company registration stretched on for weeks. Ukrainian entrepreneurs arrived with laptops, articles of incorporation, and contacts for accountants they had found through mutual acquaintances. Within a year, some of them had already closed those companies — they had set up in the wrong place, in the wrong legal form, without understanding how it was supposed to work alongside their Ukrainian structure.

The planning horizon today is different. Those relocating now are not thinking about how to get the paperwork done faster — they are thinking about what things will look like in three years, and whether they will have to start all over again.

Legal Support for Business Relocation and Process Architecture

The most common misconception about business relocation services: registering a legal entity in another country is enough, and the job is done. Registration is one action out of dozens that need to happen in parallel.

What actually lies behind the word “relocation”: legal structuring, distribution or transfer of assets, deciding what to do with the Ukrainian entity, transferring staff, opening accounts, adapting accounting to new requirements, and planning tax consequences several steps ahead.

Comprehensive business relocation services require the parallel execution of technical procedures, where accounting support for relocation unfolds simultaneously with legal protection:

• Establishing a legitimate chain of asset ownership.

• Tax modeling of cross-border transactions (transfer pricing).

• Aligning HR policy with the requirements of local legislation in the host country.

Legal support for business relocation and accounting support for relocation must run in parallel from the very beginning — not sequentially, with the lawyer first and the accountant second, but simultaneously. The decisions a lawyer makes about the structure directly affect how the accounting will look and what the tax consequences will be. These things are inseparable.

Business Relocation to Europe and Choosing a Jurisdiction

Relocating a business to Europe is a general direction, but the specific country is chosen on entirely different grounds than “where is it cheapest to open an account.” In practice, the choice comes down to three things: the type of business, the structure of the client base, and how willing the owner is to be personally present in the new jurisdiction.

Integration Specifics in the Polish Market

Poland tops this list — and not only because of geography. Relocating a business to Poland provides access to the EU market, a straightforward legal system, and a large Ukrainian community that already knows how things work there.

There is, however, a nuance that is often underestimated: the accounting for a Ukrainian company’s branch in Poland exists in parallel with Ukrainian bookkeeping, and if there is no coordination between them, discrepancies accumulate. Comparing the tax burden when relocating to Poland versus Lithuania is a task whose answer depends on the type of income and whether there are hired employees — and it is rarely straightforward.

Capitalization Specifics in Romania and Estonia

Romania offers a different appeal. Business relocation to Romania attracts primarily small businesses: the micro-enterprise regime with a rate of 1–3% of turnover represents a very low tax burden. However, obtaining Romanian tax residency status for a business requires a genuine physical presence, and “nominal” registration does not work here the way some people expect.

Estonia follows a different logic. Closing a business in Ukraine and opening a company in Estonia is a scenario chosen by IT companies where all operational activity has long been conducted online. The undistributed profit taxation model is not suitable for everyone, but for businesses that reinvest — it is optimal.

A Less Obvious Choice: Germany and Portugal

Relocating a business to Germany is a more complex and costly path. Requirements for share capital, bureaucracy, and the length of registration procedures are significant. But for manufacturing businesses or companies working with large corporate clients in the EU, it is often the only option that is taken seriously. Accounting services for Ukrainian companies in Germany are a niche area where the combination of knowledge of both Ukrainian and German law is genuinely rare.

Portugal appeared on this list later than the others. Relocating an IT company to Portugal looked attractive from a tax benefits perspective — the NHR regime offered significant advantages, although the conditions of the program have already changed several times and continue to evolve.

Business Relocation Within Ukraine: Western Regions and Incentives

Not every company has a reason or the ability to move abroad. Relocating a business within Ukraine to western regions — Lviv, Uzhhorod, Ternopil, Ivano-Frankivsk — remains a perfectly rational choice for manufacturing enterprises and businesses with physical infrastructure.

The state business relocation program provides for compensation, preferential loans, and certain infrastructure solutions. How to obtain a grant for business relocation to the western regions is a question whose answer must be verified at the time of application: program conditions and availability are subject to change.

Supporting the transfer of production facilities to the Lviv region is not just about legal paperwork. It requires logistics coordination, the re-registration of permits and licenses, and the adaptation of employment relationships to the new location.

Supporting a Business Transfer and the Fate of Ukrainian Assets

The question most often asked after a new company has already been registered: what happens now with the Ukrainian LLC or sole proprietorship?

There are actually several options, and none is universally better. The Ukrainian structure can be kept as an operational entity or as the owner of the foreign company — this is convenient if some clients or suppliers remain in Ukraine. It can also be gradually wound down, with contracts and assets transferred.

There is also redomiciliation — changing the country of registration without liquidating the legal entity. Legal support for company redomiciliation is a relatively new instrument but is already being used both within Ukraine and as a way of exiting it.

Mechanisms for Cross-Border Capital Transfer

How to transfer an LLC from Ukraine to Europe without losing assets is both a legal and a financial question. Asset sales, contributions to share capital, reorganization — each path carries different tax consequences and a different level of complexity. The choice depends on the type of assets, the presence of liabilities, and how quickly a result is needed.

There is one more scenario that is rarely discussed openly: maintaining a “dormant” Ukrainian entity with no real activity. This is not a solution — it is a deferred problem. Formal reporting obligations remain, and if they are not met, penalties accumulate. If you have decided to keep the Ukrainian LLC, you must either maintain minimal operational activity or set a clear timeline and procedure for liquidation.

Transferring the registration of a Group 3 sole proprietorship abroad is a separate and very common case with serious consequences. A sole proprietorship is not a legal entity and cannot be “transferred.” What takes place is closure in Ukraine and the registration of a new structure abroad — and along with that come questions about the tax status of income during the transition period, outstanding obligations, and how to properly prepare for deregistration.

Changing Business Tax Residency and CFC Compliance

Changing a business’s tax residency does not automatically eliminate Ukrainian tax obligations. If the actual management of a company remains in Ukraine, even with foreign registration, there is a very real risk that the State Tax Service will recognize the company as a Ukrainian tax resident. This is not a theoretical concern.

A timely consultation with an accountant on double taxation in the context of relocation protects the owner from dual claims by tax authorities. Tax planning from our team takes into account the following factors:

• Clear verification of the rules governing dividend taxation when relocating a business to the Czech Republic or other EU countries.

• Mandatory preparation and filing of controlled foreign company (CFC) reports for Ukrainian beneficiaries in 2026 to avoid substantial penalties.

• Comprehensive tax planning at the level of the individual — the company’s founder — to avoid losing Ukrainian tax residency without acquiring a new status.

Taxes in the context of business relocation are a subject where general answers simply do not apply. There are companies for which moving to Poland or Romania significantly reduces the burden. And there are companies for which, after accounting for CFC rules, dividend taxation, and local contributions, the difference turns out to be minimal or even negative.

Relocating a Sole Proprietorship Abroad and Legal Consequences

Relocating a sole proprietorship abroad is the scenario with the most common errors. A frequent mistake is registering as an entrepreneur in another country and continuing to pay the unified tax in Ukraine as if nothing has changed. Upon acquiring tax residency status in another country, obligations arise there — and they do not automatically cancel Ukrainian obligations if the income source has remained Ukrainian.

When planning to transfer the registration of a Group 3 sole proprietorship abroad, the consequences should be assessed across three dimensions. The mandatory accountant consultation on double taxation for sole proprietors relocating with BuhalteriO focuses on the following details:

• Determining the place of actual service delivery (place of performance).

• Assessing the risk of being recognized as a permanent establishment in the country of residence.

• Analyzing double taxation treaties to preserve the right to pay the unified tax in Ukraine on income from Ukrainian clients.

A consultation with an accountant on double taxation for a sole proprietor relocating is no less important than for a legal entity. Where the work is performed, where the entrepreneur lives, where the clients are — all of this affects which country has the right to tax the income. There is no general answer; there is only the specific situation of a specific individual.

Comprehensive IT Company Relocation and IP Protection

An IT business seems like the easiest to move. Clients are online, the team is distributed, the product is non-physical. In reality, there are no fewer questions than for a manufacturing company.

Structure

Most Ukrainian IT companies operated through sole proprietorships within Diia City or through LLCs with gig contracts. When relocating, these structures are either transferred to a foreign jurisdiction or restructured. Opening a branch abroad is one option. A holding structure with a parent company in another country is another. The choice depends on where the clients are, where dividends are intended to be paid, and what portion of the team is actually relocating.

Intellectual Property

When relocating an IT company, rights to software and trademarks must either remain in Ukraine or be transferred to the foreign structure. Registering a trademark in the EU during a business relocation is not just about brand protection. It is a question of where the profit center will be and how royalties between related structures will look from a transfer pricing perspective.

Team

Transitioning staff to foreign contracts during relocation is not a single scheme — it is several. Direct employment agreements with the foreign legal entity, continuation of gig contracts through the Ukrainian structure, a hybrid model. Arranging secondments during relocation is a temporary option but not a long-term one: there are time limitations, and employment relationships must eventually be formalized in the place of actual work.

Banking Infrastructure

Opening a corporate account at a European bank for a new IT company can take anywhere from two weeks to several months. Banks verify the origin of funds, ownership structure, and the genuine nature of the business. Wise Business or Revolut Business can be opened more quickly, but are not universally accepted as full-fledged bank accounts. Automating accounting during a business relocation to the cloud addresses the need for a unified financial picture — especially when teams and structures are spread across multiple countries.

Pre-Relocation Business Audit and Final Report

A pre-relocation business audit and a tax audit of the company before changing jurisdiction logically belong at the beginning of the process, not the end. Without an understanding of the current state — outstanding obligations, risks from the State Tax Service, the structure of assets and liabilities — it is impossible to properly plan either the relocation itself or what remains in Ukraine.

Full-service business relocation from BuhalteriO is structured precisely this way: first a business relocation consultation and audit, then the selection of jurisdiction and structure, followed by legal and accounting formalization, and finally operational support once both structures are running in parallel. Assistance with business relocation that begins with registration, without prior analysis, almost always costs more in the end.

The cost of business relocation depends on the scope and complexity of the specific case. The initial consultation is not a commitment — it is an opportunity to understand the real scale of the task. Whether it involves supporting a business transfer, relocating a business abroad or within Ukraine, or opening a branch overseas, the key factor in each of these scenarios is not speed — it is how thoroughly everything is prepared before the first step is taken.

Each of these processes — opening a branch abroad, changing jurisdiction, transferring assets, relocating staff — has its own timeline, its own documentation, and its own risks. Carrying them out in a haphazard, uncoordinated way means solving problems one at a time without seeing how they are connected. Having a single team support the entire business transfer from audit to operational launch represents a different level of control and predictability of outcome.

Contact BuhalteriO to get a consultation and understand which path is right for your specific situation.