In brief
An individual is a tax resident of Ukraine if they have a dwelling there, and if they also have a home abroad, according to the centre of vital interests; only when this cannot decide the matter is a stay of 183 days in a calendar year examined. A Ukrainian resident is taxed on worldwide income, usually at 18% income tax plus a 5% military levy, and Ukraine has no special tax regime for new residents. Someone resident in both countries is decided under Article 4 of the Israel-Ukraine treaty, which examines the centre of vital interests first and only then the permanent home. In Israel, the centre of life, the 183-day and 425-day presumptions and exit tax under section 100A are examined.
Key takeaways
- 1The order of tests in the Ukrainian Tax Code: a dwelling, a permanent home, the centre of vital interests, 183 days in a calendar year, and finally citizenship.
- 2A registered individual entrepreneur (FOP) is considered a Ukrainian tax resident and is taxed on worldwide income.
- 3A resident pays 18% income tax on most income, including foreign income, plus a 5% military levy since 1 December 2024. A dividend from a foreign company is taxed at 9% income tax.
- 4In the Israel-Ukraine treaty, the centre of vital interests is examined before the permanent home, unlike most treaties.
- 5Under the treaty: salary is taxed where the work is performed, a private pension only in the state of residence, a dividend from Israel up to 15% for an individual, and interest up to 10%.
- 6The annual return on foreign income is filed in Ukraine by 1 May, and the tax is paid by 1 August. In Israel, anyone claiming not to be a resident files Form 1348.
Moving to Ukraine changes two different things: the right to live there, and the country that taxes you. A residence permit does not determine tax residency, and tax residency does not give a right of stay. This guide deals with the tax side: when Ukraine treats you as resident, what it means financially, how the treaty with Israel decides when both countries claim residency, and what needs to be done in Israel. On residence permits, see Residence permits in Ukraine for Israelis.
When do you become a tax resident in Ukraine?
The Ukrainian Tax Code sets out tests in a hierarchy, and you move to the next stage only if the previous one did not decide. The first test is a dwelling in Ukraine. Someone who also has a dwelling abroad will be considered resident if they have a permanent home in Ukraine, and if they also have a permanent home abroad, if their centre of vital interests is in Ukraine. Only when the centre of interests cannot be determined is a stay of at least 183 days in the calendar year examined.
| Stage | The test | What is examined in practice |
|---|---|---|
| 1 | Dwelling | Whether you have a dwelling in Ukraine |
| 2 | Permanent home | If you also have a dwelling abroad: where the permanent home is |
| 3 | Centre of vital interests | If there is a permanent home in both countries: where your personal and economic ties are. Family members living in Ukraine is a sufficient, but not exclusive, basis |
| 4 | 183 days | A stay of at least 183 days in the calendar year, where the centre of interests cannot be determined |
| 5 | Citizenship | If that too did not decide: a Ukrainian citizen is considered resident |
The days of arrival and departure count as full days, and the days need not be consecutive. In practice, the Ukrainian tax authorities tend to give great weight to the day count, so it is worth keeping a record of every entry and exit.
According to PwC's summary of Ukrainian law, freelancers and registered individual entrepreneurs (FOP) are considered Ukrainian tax residents and are liable to tax on their worldwide income. An Israeli who registers as an individual entrepreneur to work in Ukraine should take into account that the registration itself affects their residency.
How much tax does a Ukrainian resident pay?
A Ukrainian resident is taxed on worldwide income, subject to the tax treaties. A non-resident is taxed only on Ukrainian-source income. Ukraine does not distinguish between income remitted to Ukraine and income left abroad, and it has no special tax regime for new residents like other European countries. The rates, according to PwC (checked in June 2026):
| Type of income | Income tax | Military levy |
|---|---|---|
| Salary and income from civil-law contracts | 18% | 5% |
| Foreign income (general) | 18% | 5% |
| Interest, royalties and investment gains | 18% as a rule | 5% |
| Dividend from a Ukrainian company that pays corporate tax | 5% | 5% |
| Dividend from a foreign company, for example an Israeli one | 9% | 5% |
| Inheritance and gift from a non-resident | 18% | 5% |
The military levy rose from 1.5% to 5% on 1 December 2024, under Law 4015-IX, and its calculation base is the same as the income tax base. Under the law it will return to 1.5% from 1 January of the year after martial law ends. As of November 2026 martial law is in force until 29 January 2027.
And what if I work as a self-employed person in Ukraine?
An individual entrepreneur can choose the simplified tax system, in which tax is calculated as a percentage of turnover rather than of profit. In group 3 of the simplified system the military levy is 1% of turnover, and in groups 1, 2 and 4 it is a fixed monthly amount of 10% of the minimum wage. The conditions under which a foreigner may register as an individual entrepreneur and choose the simplified system should be checked with a Ukrainian tax adviser before deciding.
Will my Israeli company be taxed in Ukraine?
Possibly. Since 1 January 2022, controlled foreign company (CFC) rules have applied in Ukraine. A Ukrainian tax resident who controls a foreign company, including an Israeli company, must include their share of the company's profits in the annual return. The rate is 9% if the funds were actually distributed to them, and 18% if not, with the option of adjustment to 9% if the money is actually received by the end of the second year after the reporting year. Under certain conditions, tax paid by the company can be offset. There are exemptions, so it is worth examining the holding structure before the move.
At the same time, the controlling owner's move to Ukraine may raise a question about the place of management of the Israeli company itself, and about a permanent establishment in Ukraine. On an Israeli company's activity in Ukraine, see An Israeli company doing business in Ukraine.
What do you have to file with the Ukrainian tax authority?
A resident who received income from outside Ukraine files an annual declaration of assets and income. According to the State Tax Service, the declaration for 2025 was due by 1 May 2026, and the tax was paid by 1 August. Anyone who did not receive documents from the foreign country in time can ask to postpone filing until 31 December of the year following the reporting year.
Foreign tax paid on the same income is credited against Ukrainian tax, but not more than the tax that would have been paid in Ukraine. To receive the credit, you attach a certificate from the foreign tax authority stating the amount of tax and the income on which it was paid. As a rule the certificate needs legalisation, unless a treaty provides otherwise. It is worth checking in advance which certificate the Israel Tax Authority will issue and whether an apostille will be required on it.
What happens with National Insurance and social contributions?
A Ukrainian employer pays a single social contribution of 22% of salary, up to a cap of 15 minimum wages a month (129,705 hryvnias in 2026). In Israel, the National Insurance Institute (Bituach Leumi) examines residency under its own rules, which are not identical to those of income tax. A social security agreement between Israel and Ukraine was signed in 2012, but we found no confirmation that it has entered into force. So before the move it is worth contacting the International Conventions Division at National Insurance and clarifying your status and the implications for future rights.
What does the treaty say when I am resident in both countries?
In the year of the move almost every family meets the conditions of both countries: an apartment in Kyiv, but also an apartment, work or children in Israel. Israel and Ukraine have a double tax treaty, effective from 1 January 2007. Its Article 4(2) decides according to a hierarchy, and it contains an important difference from most treaties: the centre of vital interests is examined first, before the permanent home.
- Centre of vital interests: the state with which personal and economic relations are closer. Family, livelihood, assets and social ties.
- Permanent home available: examined only if the centre of interests cannot be determined.
- Habitual abode: if there is a permanent home in both states or in neither.
- Nationality: if there is a habitual abode in both or in neither.
- Agreement between the authorities: if the person is a national of both states or of neither, the tax authorities decide by mutual agreement.
In most treaties, someone with a permanent home in only one state is decided by it, and the question of the centre of interests does not arise. In the treaty with Ukraine, an available apartment left in Tel Aviv does not decide on its own. If the family, work and income have moved to Ukraine, the treaty may determine that you are Ukrainian residents, and vice versa. It is worth documenting the move: a lease, the children's school enrolment, bank accounts and the place of work.
How does the treaty allocate taxing rights by type of income?
| Type of income | What the treaty provides | Article |
|---|---|---|
| Salary | Taxed in the state of residence, unless the work is physically performed in the other state. Exempt in the other state if the stay there is up to 183 days in a year and the employer is not resident there | 15 |
| Independent services | Only in the state of residence, unless there is a fixed base in the other state | 14 |
| Private pension for past employment | Only in the state of residence | 18 |
| Government pension | As a rule only in the paying state | 19 |
| Dividend | Up to 15% in the company's state for an individual; 5% for a company holding at least 25% | 10 |
| Interest | Up to 10%; 5% on a bank loan | 11 |
| Royalties | Up to 10% | 12 |
| Rent from real estate | The state where the property is located may tax | 6 |
| Sale of shares of 10% or more | The company's state may tax, up to 25% of the gain | 13(3) |
When the source state taxes, the state of residence gives a credit for the foreign tax up to the amount of its own tax on the same income (Article 23). On letting and selling a property in Ukraine, see Real estate taxation in Ukraine for Israeli residents, and on Israel's treaties in general, see Israel's tax treaties by country.
What happens in Israel when you move to Ukraine?
In Israel the test is where the “centre of life” is, under section 1 of the Income Tax Ordinance. Alongside it there are two numerical presumptions: a stay in Israel of 183 days or more in the tax year, or 30 days or more in the tax year where the total days in it and the two previous years reach at least 425. Both the taxpayer and the tax authority may rebut the presumptions. Anyone claiming not to be an Israeli resident files Form 1348, a declaration of residency, with the annual return.
- Exit tax: section 100A of the Ordinance treats someone who ceases to be an Israeli resident as having sold their assets one day before cessation. You can choose to defer payment until the actual sale.
- Income from Israel: even after cessation, Israel continues to tax Israeli-source income, such as rent from an apartment in Israel, in accordance with the treaty.
- An Israeli company: a dividend from it to a Ukrainian resident is subject to withholding in Israel, up to 15% under the treaty, and in Ukraine additional tax may apply with a credit within limits.
- National Insurance: examined separately, under the Institute's rules.
- General guide: on ending Israeli residency for any destination, see our general guide on ending Israeli tax residency.
What do you do in the first year?
- Before the move: check with an Israeli accountant the date of cessation, the exit tax implications and the holding structure in companies.
- Ukrainian tax number: obtain an RNOKPP, which is required for a bank account, a lease and the residence permit.
- Documenting the move: a lease or ownership, the children's enrolment, a bank account, an employment contract and a list of days spent in each country.
- Residency certificates: if both countries treat you as resident, request a residency certificate from the country where you claim to be resident, in order to apply the treaty.
- Withholding: update the banks and the company in Israel on your new status, so that tax is withheld according to the treaty.
- By 1 May of the following year: file the annual declaration on foreign income in Ukraine, and pay by 1 August.
- In Israel: file an annual return for the year of the move with Form 1348, and consider the reporting of assets and companies abroad.
More on relocating to Ukraine: Stay and residence routes in Ukraine · Ending Israeli tax residency · Moving abroad with an Israeli company or business · The legal checklist for families
Frequently asked questions
Do 183 days in Ukraine make me a tax resident?
Not necessarily. In the Ukrainian Tax Code the 183-day test applies only when the matter cannot be decided by the dwelling, permanent home and centre of vital interests. On the other hand, someone who has moved their home and family to Ukraine may be considered resident even before 183 days.
Are there tax benefits for new residents in Ukraine?
We found no special tax regime for new residents in Ukraine, like those in Italy, Greece or Portugal. A new resident is taxed like any resident, on worldwide income, usually at 18% income tax plus a 5% military levy.
I work remotely for an Israeli company from Kyiv. Where do I pay tax?
Under Article 15 of the treaty, salary is taxed in the state where the work is physically performed. If you are Ukrainian residents and work from there, Ukraine may tax the salary, and Israel may tax only the part performed in Israel, if any. The Israeli employer should check its withholding obligations accordingly.
What happens to my Israeli pension if I move to Ukraine?
Under Article 18 of the treaty, a private pension for past employment is taxed only in the state of residence. A government pension is as a rule taxed only in the paying state, under Article 19. The classification of National Insurance benefits needs a separate review.
Will an apartment left in Israel keep me an Israeli resident?
Not necessarily. In the treaty with Ukraine the centre of vital interests is examined before the permanent home, so an available apartment alone does not decide. However, the rent from the apartment will continue to be taxed in Israel, and the apartment is one of the factors the Israel Tax Authority weighs in the centre-of-life test.
Will I have to pay tax in Ukraine on my Israeli company's profits?
Possibly. Since 2022 controlled foreign company rules have applied in Ukraine, and a resident who controls a foreign company reports their share of its profits, at 9% if distributed to them and 18% if not. There are exemptions and the option of offsetting tax paid by the company, so the structure should be examined before the move.
When do you file a tax return in Ukraine?
A resident who had foreign income files an annual declaration of assets and income by 1 May of the following year, and pays the tax by 1 August. You can ask for a postponement until the end of the year following the reporting year if documents from the foreign country did not arrive in time.
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- Israel Tax Authority - Israel-Ukraine double tax treaty (English text)
- Israel Tax Authority - Annual return for individuals, including Form 1348
- State Tax Service of Ukraine - Foreign income declaration 2026
- OECD - Ukraine: rules governing tax residence
- National Insurance Institute of Israel - International conventions on social security
- PwC Worldwide Tax Summaries - Ukraine, Individual, Residence (reviewed 30 June 2026)
- PwC Worldwide Tax Summaries - Ukraine, Individual, Taxes on personal income
- PwC Worldwide Tax Summaries - Ukraine, Individual, Significant developments
- PwC Worldwide Tax Summaries - Ukraine, Individual, Other taxes
- Deloitte Ukraine - Personal income tax and tax return (brochure)
