Tax and banking

What taxes does a foreign-owned Ukrainian company pay?

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

Both are settled before the first invoice. The shareholder structure decides which tax regime is open, and the NBU currency rules decide when a taxed dividend can actually leave Ukraine.

Can a foreign-owned company use the simplified system?

A company owned by a foreign individual may choose the simplified (single tax) system if it meets the other conditions. A Ukrainian company in which legal entities that are not single-tax payers hold 25% or more of the charter capital cannot use it (Tax Code, subpara. 291.5.5), and a foreign parent company falls into that group. Non-residents cannot be single-tax payers themselves (subpara. 291.5.7).

So the choice is made at incorporation. A company under a foreign holding is on the general system. Changing the shareholder later is a corporate transaction with its own steps, described in how a foreigner registers a company in Ukraine.

What does the general system cost?

The base corporate profit tax rate is 18% (para. 136.1). Financial institutions other than insurers pay 25% (para. 136.1-1). Tax is charged on the accounting result, adjusted by the differences the Code lists (subpara. 134.1.1).

One number sets the administrative load: UAH 40 million of annual income. A company below it may decide to skip most of the adjustment differences (subpara. 134.1.1) and files an annual return instead of quarterly ones (para. 137.5(c)). The annual return is due within 60 calendar days after the year ends (subpara. 49.18.6); quarterly returns are due within 40 days after the quarter (subpara. 49.18.2).

When is VAT registration compulsory?

When taxable supplies over the last 12 calendar months exceed UAH 1,000,000 excluding VAT (para. 181.1). The count is a rolling twelve months. Single-tax payers of groups 1–3 are outside this obligation. A company below the threshold may register voluntarily (para. 182.1), and from that day it charges VAT on its supplies.

The VAT period is one calendar month (para. 202.1), and the return is due within 20 calendar days after the month ends (subpara. 49.18.1). A tax invoice can be stopped in the Unified Register on risk criteria set by the Cabinet of Ministers (para. 201.16); until it is registered, the buyer has no input VAT credit on it (para. 198.6).

What does one employee cost?

The 22% has a floor and a ceiling. At the employee's main place of work it is charged at least on the minimum wage, UAH 8,647 a month in 2026 (Law No. 4695-IX, Art. 8), which is UAH 1,902.34. The monthly base is capped at 20 minimum wages, UAH 172,940 (Law No. 4695-IX, Art. 32), so the contribution per person cannot exceed UAH 38,046.80 a month.

What is taken when money leaves Ukraine?

A company on the single tax still withholds the 15% when it pays a non-resident (paras. 133.1.1, 141.4.2). When a company pays dividends above the taxable profit of the year they come from, it also makes an advance profit tax payment at 18% on the excess, which it later offsets against its own profit tax. Dividends to individuals are exempt from that advance payment (subparas. 57.1-1.2, 57.1-1.3).

Services bought from a non-resident are a VAT question. For advertising, consulting, legal, accounting and similar services the place of supply is where the buyer is registered (para. 186.3), so the Ukrainian buyer charges itself VAT on the service (para. 208.2). A buyer that is not VAT-registered files a separate calculation and pays it (paras. 208.4, 208.5).

The money itself moves under NBU Resolution No. 18: periods from 1 January 2023, up to EUR 1,000,000 a month per company, or limits built from new foreign capital, loans or defence donations. The details are in taking dividends out of Ukraine.

Do tax treaties reduce the 15%?

Often, against paperwork. The company may apply the treaty rate itself if the shareholder is resident in the treaty country and is the beneficial owner where the treaty requires it (para. 103.2). It needs a certificate of residence from the shareholder's tax authority, legalised and translated (paras. 103.4, 103.5). Without it the company withholds 15% and carries the risk of a wrong rate.

Where people get stuck

• The holding decides the regime. A foreign parent above the Ukrainian company closes the simplified system under subpara. 291.5.5.
• The contribution floor. A part-time employee whose main job is with you still costs 22% of the full minimum wage.
• Treaty rate without a certificate. The difference plus penalties lands on the Ukrainian company.
• Taxed, still in Ukraine. Withholding happens on payment, while the transfer abroad must separately fit an NBU route. Profit for 2022 and earlier stays out of the general route.

FAQ

Does a foreign parent pay Ukrainian tax on the subsidiary's profit?

The Ukrainian company is a separate taxpayer (subpara. 133.1.1). The parent is taxed in Ukraine on what is paid to it, such as dividends, interest and royalties listed in subpara. 141.4.1.

Can a foreign company register for the single tax without a Ukrainian subsidiary?

Non-residents cannot be single-tax payers (subpara. 291.5.7). A non-resident trading through a permanent establishment pays corporate profit tax (subpara. 133.2.2).

Is there a lower-tax regime for IT companies?

Diia.City residents may elect a 9% tax charged on operations such as dividend payments instead of 18% on profit (paras. 136.8, 141.9-1.2). The entry criteria are in what is Diia.City.

How often does a small company file?

Profit tax once a year below UAH 40 million of income (para. 137.5(c)). VAT monthly, if registered (para. 202.1).

Is interest on a shareholder loan taxed when paid abroad?

Yes, at 15% at source unless a treaty sets a lower rate (subparas. 141.4.1(a), 141.4.2).