Impostos a Ucraïna

Company Tax

18%

Tax Rate For Foreign Companies

Foreign companies are taxed on all their revenue from Ukrainian sources, and on their profits obtained from a permanent representation in Ukraine.
A withholding tax applies to the majority of income payments for non-residents, at a rate of 15%.
Distributions from a permanent establishment (PE) to its head office, sourced from after-tax income, typically do not incur additional taxation in Ukraine, given the head office is in a jurisdiction with an effective Double Taxation Treaty with Ukraine. However, certain DTTs may impose a 'branch tax' on these distributions, akin to withholding tax on dividend income.

Capital Gains Taxation

Capital gains are treated as ordinary income and taxed at the standard corporate tax rate.

Main Allowable Deductions and Tax Credits

Most expenses incurred relative to the activities of the company are deductible for tax purposes. Assets with a value greater than UAH 20,000 and a useful life of more than one year are subject to depreciation. Depreciation is determined monthly based on different depreciation calculation methods (linear, decreasing, variable, exceptional). Goodwill cannot be amortised for tax purposes.

Organisational and start-up expenses are fully deductible and are not subject to a cap. Interest is also deductible (restrictions apply to interest paid to non-residents) as are fines and penalties (except for those paid to companies that do not pay corporation tax or are subject to a 0% tax rate). Taxes, with the exception of corporation tax, withholding taxes and non-recoverable VAT, are deductible. Employers can deduct obligatory Ukrainian social security insurance contributions, including state pension contributions charged on payroll expenses. There are no limitations on deducting the employer's payments to non-state pension organizations. R&D expenses are also deductible.

Donations to charities are only deductible up to 70% and are capped at 4% of the previous year's taxable income. This rate is raised to 8% for donations to NGOs involved in sports and physical culture. Following the introduction of martial law, the scope of recipients eligible for charitable assistance has been expanded, and the limitation on the deductibility of costs has been adjusted. The added recipients include the Ukrainian armed forces, other military units formed under Ukrainian laws, the Ministry of Internal Affairs, a central executive power body responsible for civil defence, state/communal health protection institutions, and local health protection authorities. Additionally, the deduction limit of 4% of the previous year's taxable profit does not apply to specific goods and services provided for free to non-profit organizations. These goods and services include special personal protective equipment (helmets, body armour), technical observation devices, medicines and medical devices, personal hygiene products, food, and other items, as determined by the Cabinet of Ministers of Ukraine.

Large taxpayers in Ukraine can carry forward tax losses with certain limitations. Specifically, they can utilize up to 50% of accumulated tax losses from previous years in their current tax return. Any unused tax losses are carried forward to future periods until fully utilized. If tax losses are less than 10% of the positive tax base, they may be fully utilized. Ukrainian tax legislation does not allow for refunds of losses carried back.

Resident companies would increase the taxable basis for corporate income tax by 30% of the value of goods, works and services sold to residents of low-tax jurisdictions and foreign companies having special legal forms.

Enterprises in the aircraft industry in Ukraine may benefit from temporary corporate income tax exemptions. Incentives are also available for entities founded by public institutions for disabled people. Companies engaged in green tariff power supply activities can use the cash method for corporate income tax determination until 2024. A special tax regime, "Diia City," exists for IT companies and tech start-ups. Diia City residents can choose between the standard corporate income tax regime with an 18% rate on adjusted profits or a special regime with a 9% tax on certain payments (e.g., dividends). Additionally, a reduced 5% individual income tax rate applies to salaries of Diia City employees, gig specialists, and remuneration for work under service agreements and transfer of rights to such works.

Other Corporate Taxes

Until 31 December of the year following the end of martial law, no payment is due for land occupied or under military operations as determined by the Cabinet of Ministers of Ukraine. Separate taxes apply to buildings and land. Land tax is imposed on owners/users at rates generally up to 12% for legal entities and up to 3% for individuals, based on the land's estimated value depending on location and use. Legal entities, including nonresidents, owning residential or nonresidential real estate are subject to a tax of up to 1.5% of one minimum wage as of 1 January of the reporting year per square meter owned. If the total area of real estate owned exceeds 300 m² for apartments and/or 500 m² for houses, the tax amount increases by UAH 25,000 per property per year.

Salary or similar employment compensation paid to an employee is subject to a unified social security contribution at a rate of 22%. The remuneration for these purposes is capped at 15 times the minimum wage, which was UAH 8,000 per month as of 1 April 2024.
A mandatory pension fund contribution applies to certain transactions at rates of 1% for land/buildings, 3%/4%/5% for vehicle purchases, 10% for the governmental plate mark on jewellery, and 7.5% for the usage of mobile services.

State duty is imposed on the transfer of real estate and vehicles. A local transport tax of UAH 25,000 is charged on owners of passenger cars with an average market value exceeding 375 minimal salaries (i.e. UAH 2,512,500 for 2023) and less than five years old.

Companies that discharge contaminants into the environment or dispose of waste are subject to an environmental tax, whose rate varies according to the level of contamination. Companies engaged in extracting mineral resources are subject to specific taxation.

Further taxes may be levied at the discretion of the local authorities.

Other Domestic Resources

State Tax Service of Ukraine

Tax Rate

Allowable Deductions and Tax Credits

There are deductions for Ukrainian mortgage expenses, donations to qualified charities (up to 4% of the taxpayer's taxable income, increased to 16% from 2022), tuition fees paid to Ukrainian universities and contributions to voluntary life/pension insurance (only for tax residents receiving employment remuneration in Ukraine, limited to UAH 4,240 per month per taxpayer as of 2024). Interest on a qualified mortgage for the taxpayer's main residence is deductible.

In general, amounts not deducted from the income of the reporting year cannot be carried forward, and all expenses should be properly documented.
Private entrepreneurs registered under the general tax regime may deduct business expenses and depreciation charges under the general tax regime.

Special Expatriate Tax Regime

The personal income tax for both Ukrainian and foreign nationals varies depending on their tax residency status. Ukrainian tax residents are subject to personal income taxation on their worldwide income, whereas non-residents are only subject to taxation on the Ukrainian-sourced portion of their income (defined as employment income from a Ukrainian entity/business or personal income received from Ukraine).
The same tax rates generally apply to tax residents and non-residents.