A foreigner receiving income from a Ukrainian source automatically becomes subject to Ukrainian tax legislation. The issue of double taxation arises when two states simultaneously \u2014 Ukraine and the country of residence \u2014 claim tax on the same income. However, the existing system of international conventions and the provisions of the Tax Code of Ukraine provide foreigners with specific legal tools to avoid this.<\/p>\n\n\n\n
Non-resident status determines the scope of tax obligations in Ukraine. A foreigner receives this status if they do not meet the residency criteria under the TCU.<\/p>\n\n\n\n
A foreigner’s tax status is determined by the following criteria:<\/p>\n\n\n\n
It is precisely non-resident status that determines which income is subject to taxation in Ukraine \u2014 only that which has its source on Ukrainian territory.<\/p>\n\n\n\n
Ukraine does not apply discriminatory rates for foreigners \u2014 non-residents pay the same basic rates as Ukrainian citizens. The current rates for income from Ukrainian sources are shown below.<\/p>\n\n\n\n Income in foreign currency is converted to hryvnias at the NBU exchange rate on the date of receipt. At the same time, most DTT agreements do not cover the military levy \u2014 it is paid separately.<\/p>\n\n\n\n Ukraine has concluded double taxation treaties (DTT) with more than 70 countries. The convention determines which state has the primary right to tax a specific type of income and eliminates the conflict between two jurisdictions.<\/p>\n\n\n\n The practical application of a DTT convention is implemented through three mechanisms:<\/p>\n\n\n\n To apply any of these mechanisms, the foreigner is required to provide the employer or tax authority with a legalised certificate of residency from their country before the income is paid.<\/p>\n\n\n\n From 1 April 2023, foreigners gained the ability to conduct business with Ukraine without physically relocating. E-residency is registration through the Diia application following financial and security screening.<\/p>\n\n\n\n An e-resident receives the following opportunities and conditions:<\/p>\n\n\n\n Citizens of the aggressor state russia, persons on the FATF list, and foreigners who already have active income in Ukraine (other than passive income) cannot become e-residents. E-residency is the optimal tool for foreigners conducting business remotely and seeking to minimise administrative burden.<\/p>\n\n\n\n Tax authorities accept only officially executed documents. A verbal description of the situation or a reference to a convention without supporting paperwork does not constitute grounds for PIT exemption or the application of a preferential rate.<\/p>\n\n\n\n The standard package of documents for a foreigner includes:<\/p>\n\n\n\nType of Income<\/strong><\/td> PIT Rate<\/strong><\/td> Military Levy<\/strong><\/td><\/tr> Salary from a Ukrainian employer<\/td> 18%<\/td> 5% (from 01.01.2025)<\/td><\/tr> Income from real estate in Ukraine (first sale, owned for more than 3 years)<\/td> 0%<\/td> 0%<\/td><\/tr> Income from real estate (other cases)<\/td> 18%<\/td> 5%<\/td><\/tr> Dividends from Ukrainian companies<\/td> 18%<\/td> 5%<\/td><\/tr> E-resident income (single tax, group 3)<\/td> 5% (within the limit)<\/td> \u2014<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n How the Convention Protects a Foreigner from Double Taxation<\/strong><\/h2>\n\n\n\n
The Method of Foreign Tax Credit in Ukraine<\/strong><\/h3>\n\n\n\n
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E-Residency as a Legal Alternative for Foreigners<\/strong><\/h2>\n\n\n\n
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Documents to Confirm Non-Resident Status<\/strong><\/h2>\n\n\n\n