Tax and banking

Can a Ukrainian company pay dividends to a foreign owner in 2026?

Published 29 October 2026 · facts checked against the primary sources on 2026-10-29 · Ukraine For ALL, Kyiv

The tax step and the currency step are checked by different people. The company's accountant withholds the tax. The servicing bank checks the currency route before it sends a single euro. A dividend can be fully taxed and still stay in Ukraine if the route does not fit.

How much tax is withheld?

The rate depends on who the shareholder is.

A company on the simplified (single tax) system still withholds the 15% when it pays a foreign company: the Code names simplified-system payers among the residents who withhold (para. 141.4.2). For a foreign individual, Section IV of the Code taxes Ukrainian-source income on the same rules and rates as for residents (para. 170.10.1), and the company acts as the tax agent when it accrues the dividend (paras. 170.5.1, 170.5.2).

On top of the shareholder's tax, the company itself may owe an advance corporate profit tax payment. It is charged at the 18% base rate on the part of the dividend that exceeds the taxable profit of the year the dividend is paid from, and it is paid before or together with the dividend (para. 57.1-1.2). The company later offsets it against its own profit tax. Dividends paid to individuals are exempt from this advance payment (para. 57.1-1.3).

When does a treaty rate apply?

The company may apply the lower treaty rate itself, at the time of payment, if the foreign shareholder is a resident of the treaty country and, where the treaty requires it, the beneficial owner of the dividend (para. 103.2). The basis is a certificate of residence from the shareholder's own tax authority, legalised and translated under Ukrainian rules (paras. 103.4, 103.5). Without the certificate the payer withholds 15%, and the risk of a wrong rate stays with the Ukrainian company.

Which NBU route lets the money leave?

NBU Resolution No. 18 of 24 February 2022 bans cross-border currency transfers by default and lists exceptions in paragraph 14. Five of them fit an ordinary operating company. Three more, subparas. 14(46¹)–14(46³), serve groups that guarantee or borrow under foreign-listed bonds, and the conditions of 14(46) do not apply to them.

The investment, loan, donation and additional limits are used only for the purposes listed in para. 14(57), and dividends to a foreign investor are on that list.

What changed in August 2026?

NBU Board Resolution No. 90 of 10 August 2026 eased the rules from 11 August 2026. Three changes matter for dividends.

1. Group companies can share the investment limit. A related company, as defined in subpara. 14.1.159 of the Tax Code, may use another company's investment limit in full or in part. The owner of the limit gives written consent at the bank, and both companies run the operations through the same bank (para. 14(57), new paragraph added by Resolution No. 90).
2. A company formed by transformation keeps its history. For the 12-month test of the general route, the period of the predecessor company now counts as well (para. 14(46), paragraph five as amended by Resolution No. 90).
3. A new "additional" limit. Charitable cash donations made since 10 August 2026 to support defence, with military units as final recipients, open a limit of the same size for the purposes of para. 14(57), dividends included. The company proves the donations with financial statements audited by one of Deloitte, PwC, EY or KPMG, and a related company may use the limit with the owner's written consent at the same bank (para. 14(62¹), added by Resolution No. 90).

The NBU announcement of the package also lists repatriation of dividends after a change of a company's legal form among the eased areas.

What does the process look like?

1. The participants decide to pay a dividend out of the profit of a specific period. For the general route that period has to start on or after 1 January 2023.
2. The accountant calculates the shareholder's tax and, where it applies, the advance profit tax payment. Both go to the budget when the dividend is paid (paras. 57.1-1.2, 141.4.2).
3. The company chooses the currency route and gives the bank the decision, the financial statements for the period and the ownership documents. Under the general route the bank checks the 12-month and 6-month tests and runs the payment through "E-limits".
4. The bank transfers the money directly to the foreign shareholder's account abroad.

Where people get stuck

• Old profit. Retained earnings for 2022 and earlier cannot go out on the general route at all. A decision that mixes old and new profit has to be split.
• A new shareholder. An investor who bought the stake four months ago fails the 6-month test, however long the company has existed.
• Two banks. The investment and loan limits live in one bank. Moving the account requires a written request and a transfer of the limit history to the new bank.
• No certificate. A treaty rate applied without a valid certificate of residence turns into a 15% liability for the Ukrainian company, plus penalties.

FAQ

Is the EUR 1,000,000 a year or a month?

A calendar month, per company that issues the shares. The bank counts it through the NBU "E-limits" system (Resolution No. 18, para. 14(46)).

Can dividends for 2022 be paid abroad now?

The general route excludes them: it covers periods starting from 1 January 2023 and expressly excludes earlier retained earnings and reserve capital. The investment, loan, donation and additional limits list dividends among their purposes without that period condition.

Does a foreign individual shareholder file a Ukrainian return for the dividend?

The Code makes the tax on dividends final at the moment the company accrues them: the company, as tax agent, withholds it (para. 170.5.4). Income received only from tax agents does not require an annual return (para. 179.2).

Does a simplified-system company withhold tax on dividends?

Yes. It withholds 15% on dividends to a foreign company (para. 141.4.2), and 9% plus the 5% military levy on dividends to an individual (para. 167.5.4; Section XX, Subsection 10, para. 16-1).

Are interest and royalties paid abroad taxed the same way?

Yes. Interest and royalties paid to a non-resident are on the same list as dividends and carry the same 15% at source unless a treaty sets a lower rate (paras. 141.4.1(a), (c), 141.4.2).