Tax and banking

When does a foreigner become a tax resident of Ukraine?

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

The 183-day count is the best-known part of the rule and the one applied last. It decides the question only when the earlier tests give no answer. Subparagraph 14.1.213 of the Tax Code sets out the whole sequence.

How does the Tax Code decide?

The tests run in this order (Tax Code, subpara. 14.1.213(c)):

Two shortcuts sit in the same subparagraph. Registering as a self-employed person in Ukraine, or declaring Ukraine as one's main place of residence under the Code, is enough on its own to treat the person as a resident. The place where the family lives permanently, or where the person is registered as an entrepreneur, is named as sufficient evidence of the centre of vital interests.

What changes once you are resident?

A foreigner who becomes resident files an annual return for that year, listing both Ukrainian and foreign income (para. 170.10.4).

Is tax paid abroad credited?

Yes, where a treaty ratified by the Verkhovna Rada provides for it. The resident claims the credit in the annual return (para. 170.11.2). The credit cannot exceed the Ukrainian tax on the same income (para. 170.11.4), and some taxes never count: capital and property taxes, postal taxes, sales taxes and other indirect taxes (para. 170.11.3).

If the foreign documents confirming the income and the tax paid are not ready in time, the taxpayer must file an application with its tax office to move the filing deadline to 31 December of the year after the reporting year (para. 170.11.2).

How do you prove Ukrainian residency to another country?

With a certificate confirming Ukrainian tax residency for treaty purposes, issued by the State Tax Service.

Registration in the State Register of Individual Taxpayers is a precondition, so a foreigner needs a Ukrainian tax number first: see how a foreigner gets a tax number in Ukraine.

Where people get stuck

• Counting days only. A foreigner whose only permanent home is in Ukraine is resident at step 2 of the table, whatever the day count. The 183 days come into play only at step 4.
• Two residencies. Ukraine and the other country may each treat the person as resident under their own law. Where a double tax treaty exists, its residence article settles the conflict, so read it before relying on either country's view.
• Foreign income forgotten. Dividends, rent or salary from abroad go into the Ukrainian annual return in the year of residency. Foreign dividends carry 9%, most other foreign income 18%.
• A foreign certificate with no translation. A Ukrainian payer can apply a treaty rate to a non-resident only with a legalised, translated certificate from the other country (paras. 103.4, 103.5).

FAQ

Is the 183-day test a calendar year?

The Code counts at least 183 days, including the days of arrival and departure, during a period or periods of the tax year (subpara. 14.1.213). The test applies only when the home and centre-of-interests tests give no answer.

Does a temporary residence permit make me a tax resident?

The Tax Code uses its own tests. A residence permit is a migration status, and tax residency follows subpara. 14.1.213: home, centre of vital interests, then 183 days.

Can a company be a Ukrainian tax resident?

Yes. Every company formed under Ukrainian law is resident (subpara. 14.1.213(a)). A foreign company managed from Ukraine may also acquire Ukrainian residency through its place of effective management (subpara. 133.1.5), which is one of the refusal grounds listed on the certificate card.

How long does the residency certificate take?

Ten calendar days, free of charge, according to the State Tax Service card for this service.

What rate applies to a resident's foreign salary?

18% personal income tax (paras. 167.1, 170.11.1) plus the 5% military levy (Section XX, Subsection 10, para. 16-1), reported in the annual return.