Tax Residency: How to Obtain Status in Ukraine Quickly
An IT professional from Kharkiv relocated to Warsaw in February 2022. He kept his sole proprietorship registered in Ukraine — clients were used to it, payments were convenient, and the system was already in place. A year passed, then another. He now has a residence permit in Poland, a Polish bank account, and a child enrolled in a Polish school. Where is he now a tax resident — in Ukraine or in Poland? And does he himself know the answer to that question?
In most cases — no. And that is precisely where the problems begin.
What Tax Residency Is and Why It Is Not the Same as Citizenship
A passport and tax status are two different things, and they frequently do not align. Determination is based on specific criteria: where a person actually lives, where their family is, where their property is, where their business operates.
The primary indicator in Ukraine is 183 days of presence per year. 183 days is a starting point, not a verdict. A person who has spent half a year abroad can retain Ukrainian residency if they can demonstrate that the centre of their vital interests has remained here.
How to confirm the centre of vital interests in Ukraine for the tax authority is a question of evidence: property owned, family, an active business, social ties. How to prove Ukrainian tax residency while spending more than 183 days abroad is entirely feasible, but the task requires preparation.
Residency Status Determination Matrix in the EU
Extended periods of time abroad inevitably create situations where two states simultaneously claim a person’s taxes.
| Jurisdiction (Direction) | Key Criterion for Status Determination | Specifics for Ukrainian Expats | Risks of Automatic Reclassification |
| Ukraine | Existence of a registered sole proprietorship, real estate, and the family’s permanent place of residence. | A simplified procedure for obtaining Ukrainian tax resident status through digital services is in effect. | The risk of double taxation and conflicting tax residency claims arises. |
| Poland | Presence for more than 183 days per year or the existence of a centre of interests. | Tax residency in Poland is particularly relevant for Ukrainians whose children attend local schools. | Strict penalties for dual tax residency apply to Ukrainian citizens. |
| Germany | Existence of a permanent dwelling (even rented) and an official employment contract. | The Ukraine-Germany tax residency framework operates strictly, with priority given to local-source income. | Loss of tax resident status is possible due to the existence of housing abroad. |
Determining tax residency based on the centre of vital interests is a mechanism now actively used by those who left after 2022 and do not wish to sever their connection with the Ukrainian tax system.
Ukrainian Tax Residency Certificate: Why It Is Needed and How to Obtain It
A Ukrainian tax residency certificate is required each time it is necessary to confirm status before a foreign bank, employer, or tax authority. Without it, a double taxation avoidance convention cannot be applied — which means paying the full rate where a reduced rate would otherwise apply.
Digitalisation of Interaction with Fiscal Authorities
- An application for a tax residency certificate is submitted online through the taxpayer’s electronic cabinet. The correct subdivision, the correct form, and an understanding of exactly what is being confirmed are all required.
- A residency certificate obtained online through the Diia platform is another channel that is gradually being developed.
The cost of a Ukrainian tax resident certificate depends on whether it is obtained independently or with professional support. The state fee is nominal, but preparing the document package and communicating with the STS take time.
Legalisation of Documents for Foreign Jurisdictions
Obtaining a Ukrainian residency certificate with an apostille for Spain (or any other European country) is a separate step required when the document is to be used in a country that mandates legalisation.
A certificate of Ukrainian tax resident status for exemption from withholding tax is a specific request from companies that pay dividends or royalties to non-residents and wish to apply convention-based benefits.
Tax Residency of a Sole Proprietor in the Context of Relocation
Tax residency for sole proprietors is a particularly acute topic. A sole proprietorship is legally tied to Ukraine, but if the owner is actually living in another country, a conflict arises: Ukraine considers them a resident, and so does the country of residence.
Risks of Cross-Border Neobanking and Digital Nomadism
Tax residency of a sole proprietor when receiving income via Wise or Revolut is a specific case where the residency question intersects with the automatic exchange of information under CRS.
Tax residency for Ukrainian IT specialists in Germany is one of the most frequent requests among those who relocated under an employment contract. There is an important detail here: Germany does not ask where a person is registered as a sole proprietor.
If there is a permanent dwelling and regular income from a German employer, Germany considers that person its resident. What then happens with the Ukrainian sole proprietorship depends on whether it is still active and whether the centre of interests has remained in Ukraine.
How to avoid double taxation when working remotely in Poland is a question with no single answer. Everything depends on the structure of income, the number of days spent there, and whether the convention between Poland and Ukraine applies to the specific type of income in question.
Tax residency of digital nomads in Ukraine is still a new topic without clear legislative regulation. A person without a fixed place of residence who lives in different countries for several months at a time may find themselves in a situation where no country is formally their tax resident — or conversely, where several countries claim them simultaneously.
Tax Residency of a Legal Entity and the Digital Sector
Tax residency of a legal entity in Ukraine is determined by the place of registration or the place of actual management. Residency for foreign companies arises if management is carried out from Ukraine, even if the company is registered in Cyprus.
Tax residency of the director of a foreign company in Ukraine is a related risk: a resident director managing a structure from here may bring the company under Ukrainian taxation.
Tax residency under Diia City applies to IT companies with special status: the company itself remains Ukrainian, but the residency of founders and gig specialists is determined separately.
Taxation of income from crypto assets for Ukrainian residents in 2026 is an area where the obligation to declare already exists, while the rules are still being formed. Taxation of dividends from a foreign company when a resident certificate is held grants the right to a reduced convention rate — but does not remove the obligation to declare.
Avoiding double taxation with the assistance of a lawyer is a legitimate instrument that most people do not use simply because they are unaware of its existence.
Loss of Ukrainian Tax Residency and CRS Consequences
A change of tax residency can have long-term consequences. Loss of Ukrainian tax residency means a change in the taxation regime: income from Ukrainian sources for non-residents is taxed at higher rates, and access to certain benefits is lost.
Loss of tax resident status due to the existence of housing abroad is one of the least obvious risks, which people typically discover after the fact.
When a change of status occurs, a step-by-step procedure is carried out:
- The official recognition of an individual as a Ukrainian non-resident is conducted in accordance with the 2026 procedure, with correction of registration data at banks.
- A specialist consultation is provided on the automatic exchange of information under CRS for account holders, with the aim of minimising fiscal claims.
- Confirmation of residency for the transfer of capital abroad is carried out in accordance with NBU limits.
Penalties for failure to notify of a change in tax residency and penalties for dual tax residency are real risks for those who disregard the question of their status.
CRS operates straightforwardly: a bank in Poland, the Czech Republic, or Estonia transmits account information to the local tax authority, which in turn transmits it to Ukraine’s STS if the account holder is a Ukrainian resident.
The automatic exchange of tax information under CRS in 2026 covers virtually all significant financial institutions in Europe. An account that “nobody knows about” is, in reality, already known — the only question is whether the tax authority has yet turned its attention to it.
Consultations on tax residency matters, legal assistance in disputes with the tax authority regarding non-resident status, accounting support for Ukrainian non-residents, tax planning, and change of residency — BuhalteriO handles all of these tasks. Contact us to resolve your specific situation before it becomes a problem.