Professional International Taxation Services in Ukraine
A Ukrainian citizen has been living in Warsaw for two years, has a sole proprietorship registered in Ukraine, and holds an account at a Polish bank. Does he pay taxes in Poland? Is he required to report the Polish account to Ukrainian authorities? What happens if he does not? Three questions — and none of them has an obvious answer without analysing the specific situation.
International taxation is not about paying less. It is about understanding where and what you are obligated to pay, and avoiding penalties in places where you had no idea any obligations existed.
CFC Reporting 2026 and Foreign Company Compliance
CFC reporting in 2026 is the most common request to international tax consultants among Ukrainians. Controlled foreign companies — that is, foreign structures managed or owned by Ukrainian residents — came under direct regulation several years ago, and far from all owners have yet understood the implications.
Procedure for Recording the Profits of Foreign Structures
Comprehensive CFC (controlled foreign company) support involves not only filing declarations but also in-depth tax modelling. Capital owners need to take into account the following regulatory requirements:
- Knowing the technical procedure for submitting a CFC report through the electronic cabinet in 2026 without procedural errors.
- Conducting a preventive tax audit of foreign assets before filing the declaration in order to adjust the financial result.
- Timely calculating the taxation of dividends received from abroad, avoiding duplicate fiscal claims.
Penalties for failure to submit a CFC report in 2026 are substantial. Non-submission and submission with errors constitute separate violations carrying different sanction amounts. Liability for failure to disclose the beneficial owner of a foreign structure is another risk that owners of offshore or holding companies typically learn about only after the State Tax Service (STS) has already sent a request.
The Double Taxation Convention and Protection
The double taxation convention between Ukraine and a specific country does not provide protection automatically. It grants the right to protection — but only if documents are properly prepared, residency is confirmed, and the correct article of the convention is selected for the specific type of income. Missing one step means the preferential rate does not apply, and an additional tax payment plus a penalty for underpayment become entirely realistic outcomes.
Protecting the Income of Residents Abroad
Avoiding double taxation for sole proprietors in Poland is arguably the most typical case of the past two years. An entrepreneur is registered in Ukraine, lives in Warsaw, and works with Polish or international clients. Whether they are a tax resident of Ukraine or Poland depends on the length of stay, the centre of vital interests, and several other criteria.
The following instruments are used for the legal settlement of fiscal status:
- Official Ukrainian tax residency, confirmation of which requires obtaining paper or digital certificates from the STS.
- Timely submission of an application and a certificate of Ukrainian tax resident status for foreign tax agents.
- Official receipt of a certificate of taxes paid in Germany for the Ukrainian STS in order to carry out the credit procedure in Ukraine.
A consultation on tax residency during an extended stay abroad is needed not to “optimise” anything, but simply to understand one’s status and avoid receiving claims from both countries simultaneously.
The calculation of tax on dividends from foreign investments in Ukraine depends on whether a convention exists between the countries and what rate it stipulates. A reduction of the withholding tax on dividend payments is possible precisely through the correct application of convention rates — but only if all required documents have been prepared.
Automatic Exchange of Tax Information under CRS and Associated Risks
The automatic exchange of tax information under CRS is a system that has been operating between most developed countries for several years.
| Control Category | Features of Fiscal Monitoring in Ukraine | Critical Risks for the Account Holder |
| CRS System (Traditional Banks) | Full account verification under the CRS system — what businesses need to know: the STS automatically receives data on account balances in EU countries. | Assessment of taxes on undeclared foreign income of companies and individuals. |
| Digital Platforms (Revolut, Wise) | A current question: whether taxes in Ukraine must be paid on income received via Revolut or Wise, as these systems are also integrated into the exchange. | Strict penalties apply for failure to submit a notification of opening an account abroad. |
| Inheritance and Gifts | Any capital assets are subject to unconditional declaration at the beneficiary’s place of registration. | Unplanned tax consequences arise from receiving an inheritance from abroad in Ukraine. |
Transfer Pricing: Services for International Business
Transfer pricing — documentation preparation services — applies to companies that have transactions with related non-resident parties. Preparation of transfer pricing documentation for IT companies is one of the most common cases: royalty payments, services between related structures, and intra-group financing.
Optimisation and Compliance for Remote Business Models
- Taxation of the profits of a foreign company without establishing a permanent establishment is a separate scenario where the risk of permanent establishment must be assessed in advance.
- Payment of royalties to a non-resident: tax consequences and restrictions is a topic where mistakes are costly. The withholding tax rate, the application of reduced convention rates, and the requirements for confirming the beneficial owner — all of this must be addressed before the payment is made, not after the bank has raised questions.
- Taxation of the profits of a foreign company without establishing a permanent establishment is a scenario relevant to those who sell into Ukraine remotely. How to repatriate profits from a foreign company to Ukraine with minimal taxation is a question whose answer depends on the structure: whether a CFC exists, which convention applies, and whether there is genuine substance in the foreign jurisdiction.
- Structuring international business and international tax planning are broader tasks that begin with an analysis of the current situation. Switching from foreign residency to Ukrainian residency: tax risks is a separate case that is now becoming more relevant in the reverse direction than it was several years ago.
- Taxation of foreign company representative offices in Ukraine is an adjacent topic that intersects with both CFC rules and transfer pricing simultaneously. If a foreign company has a permanent establishment in Ukraine, it becomes an independent corporate income taxpayer. Transactions between the representative office and the parent structure fall under transfer pricing control if they exceed threshold values.
- Taxes for IT companies abroad is a separate case in this context: the distribution of functions between the Ukrainian and foreign parts of a group determines where the profit is generated and where it is taxed. A tax audit of foreign assets before filing the declaration allows the overall picture to be put in order before the report is submitted to the STS, rather than having to correct it afterwards.
Poland, Estonia, and Others: Taxes for Business
Taxes in Poland for Ukrainian businesses are the most common request among those who relocated or opened a structure after 2022. The Polish system is relatively straightforward, but there are nuances regarding VAT, social contributions, and the recognition of expenses that significantly affect the actual tax burden.
Taxes in Estonia for Ukrainians are attractive primarily because of the model of taxing undistributed profits. However, there is a condition: the company must have a genuine economic presence in Estonia, not simply be registered there. Without this, the Ukrainian STS may treat it as a CFC and tax its profits in Ukraine.
A consultation on the application of the MLI convention when paying interest is a highly specialised but important request. The MLI significantly changed the conditions for applying convention benefits for many countries, and what worked before 2019–2020 may no longer be applicable today.
Tax consequences of receiving an inheritance from abroad in Ukraine is another area where people regularly discover their obligations after the fact. Declaration, valuation, payment — all of these have deadlines, and missing them results in penalties.
Tax audits of international transactions, legal support for foreign economic activity, international tax compliance, entry into international markets with tax consulting, and minimisation of taxes on the export of services — BuhalteriO handles all of these tasks. Contact us for a consultation to clarify your specific situation.