Work Culture in Ukraine

The regime was introduced by Presidential Decree No. 64/2022 of 24 February 2022 “On the introduction of martial law in Ukraine”, approved by Law No. 2102-IX of 24 February 2022. The official portal of Ukrainian legislation gives that decree as in force, in its redaction of 25 July 2026, on the basis of Decree No. 596/2026. The text of the decree carries a series of successive extension limbs; the last of them provides that the period of validity of martial law in Ukraine is extended from 05:30 on 2 August 2026 for a period of 90 days, in accordance with Presidential Decree No. 596/2026 of 13 July 2026. That extension decree was itself approved by Law No. 4928-IX of 14 July 2026. Sources consulted on 30 August 2026.

The regime itself is defined by Law No. 389-VIII of 12 May 2015 “On the legal regime of martial law”, in force in its redaction of 4 March 2026. Its first article defines it as a special legal regime conferring on State bodies, on the military command, on the military administrations and on local self-government the powers they need, and providing for a temporary limitation of constitutional rights and freedoms, with an indication of how long those limitations last. Article 7 states that the regime ends on the expiry of the period for which it was introduced, and that the President may, before that term, issue a decree lifting martial law over the whole territory or in certain localities, on condition that the threat of attack or the danger to the independence of the State and to its territorial integrity has been removed, which must be announced immediately through the media.

Article 8 enumerates the measures that the military command, together with the military administrations where they have been formed, may put in place, alone or with the assistance of the executive authorities and of local self-government, within the limits of the restrictions laid down by the presidential decree: a curfew, a special entry and exit regime, a limitation on the freedom of movement of citizens, foreign nationals and stateless persons and on the movement of vehicles, checks on documents and, where necessary, inspection of belongings, vehicles, luggage and goods, of office premises and of citizens’ homes, a ban on gatherings, restrictions on the choice of place of stay or of residence, and evacuation. The point carrying the document checks and the inspections expressly reserves the limits that the Constitution of Ukraine lays down. That enumeration is not closed: its last point covers the other measures provided for by the norms of international humanitarian law.

Article 8 also provides for the compulsory expropriation of private or communal property for the needs of the State, on the conditions laid down by law. Article 23 provides that, where full prior compensation has not taken place, it takes place afterwards, on the conditions laid down by law, and that the former owner may apply to the courts for the return of property preserved after the regime is lifted. One exception is attached to it: where the property is confiscated for the benefit of the State under a sanction provided for by the Ukrainian law on sanctions, no compensation is paid.

Article 21 is the one that governs the position of a foreign national: the legal status of foreign nationals, of stateless persons and of foreign legal entities present on Ukrainian territory during martial law is determined by the Constitution and the laws of Ukraine and by the international treaties ratified by the Verkhovna Rada. That article has a single part and attaches no exception to the rule. Article 22 lays down an express limit: the introduction of martial law cannot serve as a ground for torture or for cruel or degrading treatment or punishment. Article 20 refers to the Constitution for the rights that cannot be restricted in any circumstances.

Article 3 of Decree No. 64/2022 states that the constitutional rights and freedoms capable of being limited are limited for the period of application of the legal regime of martial law. The successive extension limbs all sit under the first article of the decree, and article 3 carries no mention of amendment. The constitutional articles that article 3 refers to cover the inviolability of the home, the secrecy of correspondence, private life, freedom of movement and the free choice of place of residence, freedom of expression, participation in the management of public affairs and the right of assembly for citizens, the right of property, the freedom to conduct business, the right to work, the right to strike and the right to education. Article 64 of the Constitution sets out, for its part, the rights that cannot be restricted, even under this regime.

The procedure for the special entry and exit regime is laid down by Cabinet of Ministers Resolution No. 1455 of 29 December 2021, in force in its redaction of 7 August 2025, adopted on the basis of point 6 of the first part of article 8 of Law No. 389-VIII. That text defines the special regime as a set of measures intended to prevent the unauthorised movement of persons and vehicles, and it defines the pass as the document issued by the commandant’s office that authorises entry into a territory subject to that regime or exit from it. The reinforced checkpoint it defines is set up at the entrances to and the exits from that territory, with the exception of the State border. Crossing the State border at the crossing points takes place having regard to the restrictions established by legislation. Among the grounds for refusing a pass that this text sets out is the fact, for a foreign national or a stateless person, of not presenting their passport document or a document attesting the lawfulness of their stay on Ukrainian territory.

The entry rule is laid down by article 9 of Law No. 3773-VI of 22 September 2011 “On the legal status of foreign nationals and stateless persons”, in force in its redaction of 1 July 2026. Foreign nationals and stateless persons enter Ukraine on presentation of the passport document defined by that law or by a treaty and with a visa obtained in the prescribed form, “unless otherwise provided by the legislation or the international treaties of Ukraine”. The same part places outside that rule persons who cross the border in order to be recognised as refugees, to obtain complementary or temporary protection, or to seek asylum. The third part of the same article provides that the length of the stay is set by the visa, by legislation or by a treaty.

Article 21 of the same law adds a separate condition of entry: entry, stay and transit presuppose sufficient means, or the possibility of obtaining them lawfully on Ukrainian territory. The law sets no amount; it leaves it to the Cabinet of Ministers to set that amount and the way it is to be evidenced.

The law enumerates no State whose nationals are exempt from the visa requirement. It delegates: its article 15 refers to “nationals of States whose citizens may enter Ukraine without a visa in accordance with the legislation of Ukraine or an international treaty of Ukraine”. The first limb of that delegation points to presidential decrees taken nationality by nationality. The enumeration the public consults is the one published by the ministry of foreign affairs, in the form of a table by nationality of citizenship and by type of travel document, whose heading carries the words “as of June 08, 2023”. That table is an administrative statement of the rule and not a normative instrument. The ministry sets out its scope: it gives the conditions of entry for a private or tourist trip, and, to enter for the purpose of study, work or another activity, an appropriate visa is usually required. It adds that the holder of a refugee document within the meaning of the Geneva Convention and a stateless person always need a visa to enter. The law carries, for its part, at its article 9, the exclusion of persons who cross the border in order to be recognised as refugees, to obtain complementary or temporary protection or to seek asylum; how the two statements fit together for one and the same person is not established.

The rules on issuing visas are approved by Cabinet of Ministers Resolution No. 118 of 1 March 2017 “On approval of the Rules on issuing visas for entry into Ukraine and transit through its territory”, in force in its redaction of 21 May 2025. That text lays down the visa types and their durations. It does not enumerate the States whose nationals may obtain an e-Visa either: the list of eligible nationalities is maintained by the ministry of foreign affairs on its own site.

One nationality shows why the date of the table matters. For citizens of the United Kingdom of Great Britain and Northern Ireland, Presidential Decree No. 28/2020 of 29 January 2020, in its redaction in force of 12 December 2025, establishes a visa-free regime of entry and transit “for the period from 31 January 2020 to 30 January 2027”, where the length of the stay does not exceed 90 days for 180 days. The note carried on that row of the ministry’s table refers for its part to Decree No. 8/2024 of 9 January 2024, whose stated end date is 30 January 2025, a date now passed. Decree No. 28/2020 has been amended since, most recently by Decree No. 921/2025 of 10 December 2025, which carries that period to 30 January 2027.

On the oldest bands, the table and the decrees do not say the same thing. The presidential decrees of 2005 on visa-free entry for nationals of the member States of the European Union, of Switzerland and of Liechtenstein, and for citizens of Canada, of the United States and of Japan, together with the decree of 2012 for Croatia, state a length of stay not exceeding 90 days, with no 180-day window. The ministry’s table places those nationalities in the “90 days for 180 days” band. The instrument that adds the 180-day window to those older regimes could not be identified, and the legislative portal’s cards for several of those 2005 decrees carry no mention of force. For a national of one of those States the regime stated here is therefore the one in the ministry’s table, as it stood on 8 June 2023: visa-free entry for 90 days at most for 180 days.

The law distinguishes the refusal to issue a visa, the refusal of entry and the annulment of a visa. The refusal to issue a visa is discretionary: article 11 provides that a visa “may be refused”, and it sets out the grounds, among them a threat to national security or to public order, entry in the database of persons who are not admitted, production of a passport document that is invalid or belongs to another person, production of knowingly false information or of falsified documents, the absence of a valid medical insurance policy where one can be taken out in the State in which the application is filed, the absence of sufficient means, the absence of evidence of the purpose of the stay, and the refusal to provide biometric data.

The refusal of entry is mandatory: article 13 provides that entry “is not permitted” in the cases it sets out, in particular the interests of national security, the protection of health and of the rights and legitimate interests of Ukrainian citizens and of other persons residing in Ukraine, the production of knowingly false information or of falsified documents, a passport document or a visa that is falsified, damaged, not in conformity with the established model or belonging to another person, a breach at the crossing point of the rules on crossing the border, of customs rules or of sanitary norms, and the failure, during an earlier stay, to comply with a decision of a court or of an administrative authority. The annulment of a visa, provided for by article 12, is yet another decision, and it may be challenged in the forms laid down by law.

The decisions belong to separate authorities. The visa is decided by a Ukrainian diplomatic mission or consular post, by the ministry of foreign affairs or by one of its representations on Ukrainian territory. Registration on entry is carried out at the crossing points by the border guard bodies. A three-year ban on entry may be decided by the central authority responsible for migration, by the Security Service of Ukraine, by the border guard bodies or by an authorised unit of the National Police. Texts consulted on 30 August 2026.

The basic temporary stay is laid down by Cabinet of Ministers Resolution No. 150 of 15 February 2012, in force in its redaction of 10 May 2026, which approves the procedure for extending the stay and the temporary residence of foreign nationals and stateless persons. Its point 2 distinguishes two situations: nationals of States subject to the visa requirement may stay for the period authorised by the visa and within the limits of its validity, unless a treaty sets another period; nationals of States exempt from the visa requirement may stay 90 days at most for 180 days, unless legislation or a treaty sets another period. The same point adds that the procedure for calculating that period is established by the ministry of internal affairs.

The extension of the stay is decided by the State Migration Service and its territorial bodies, where justified grounds exist and on production of supporting documents, for the period during which those grounds exist. The list of grounds the text gives is open: it cites medical treatment, childbirth, care for a sick member of the family, a forced stop on the territory owing to exceptional circumstances, the settlement of an estate, the existence of grounds for issuing a permanent or a temporary residence permit, the filing of an application for an immigration permit or for the acquisition of nationality, and it ends with the other circumstances that make departure impossible. Persons exempt from registration, and those registered with the ministry of foreign affairs and its representations, are outside that arrangement.

The application for an extension is made by the foreign national or stateless person of full age and capacity, or by the legal representative of an adult lacking capacity, AND by the host party, no later than three working days before the end of the stay authorised on Ukrainian territory. The starting point of that period is the end of the established period of stay, and not arrival. The text provides for two regimes of late filing: where the application is made out of time but before the end of the authorised stay, it is accompanied by the documents establishing the grounds that make departure impossible; where the period of stay has been exceeded, the application is received only after the foreign national or stateless person AND the host party have been held administratively liable.

The head of the territorial body of the State Migration Service, or a person authorised by them, decides on the extension or on its refusal in two cases which the text distinguishes: for persons staying temporarily on the territory, for up to 180 days from the date of the last entry, and not from the date of the decision; for those who have applied for an immigration permit or for the acquisition of nationality on Ukrainian territory, for the period needed to examine that application and to issue the permanent residence permit, or to acquire nationality. The decision may also be taken by the head of the State Migration Service, or by a person authorised by them, irrespective of the periods of stay. The extension exists only once the corresponding entry has been made in the passport document or in the stateless person’s identity document. A decision reducing the stay states the period within which the person is required to leave Ukraine, and that period cannot exceed five calendar days from the day the decision is taken. A refusal to extend, a reduction of the stay or the invalidation of an extension may be challenged within ten working days from the day the decision is brought to the person’s notice, before the State Migration Service where it comes from a territorial body, or before the courts.

That same text carries a single provision specific to martial law: during the period of martial law and for the 30 days following its lifting or its end, the limits on the length of stay in its point 2 do not apply to foreign nationals and stateless persons who have come to work as correspondents or representatives of foreign media and who are accredited as representatives of media in the forms laid down under the legal regime of martial law. Accreditation is the condition of that exemption.

The temporary residence permit presupposes, as a rule, a long-term visa. Article 5-2 of Law No. 3773-VI provides that foreign nationals and stateless persons are required to obtain a long-term visa with a view to obtaining a temporary residence permit in Ukraine, “unless otherwise provided by the laws or the international treaties of Ukraine”. That requirement does not apply to persons in respect of whom a decision has been taken to open the procedure for recognition as a refugee or as a person in need of complementary protection, nor to persons falling within certain categories the law designates, nor to the members of their family. The application for a residence permit repeats the same requirement: the file includes the passport document carrying the long-term visa, except for persons who are not required to obtain that visa.

The grounds opening the right to a temporary residence permit are enumerated by article 4 of the same law, and the duration of the permit is set by its article 5-1, whose last point closes the series without enumerating: in all the other cases provided for by article 4, the permit is issued according to the documents produced, without exceeding one year. The fourth part of article 4 is the one on employment: persons who have come to Ukraine to be employed or to conclude a gig contract, who have obtained the permit to employ foreign nationals and stateless persons together with a temporary residence permit, are regarded as staying lawfully on the territory for the period of their work in Ukraine. The twelfth part is the one on the supervision of a Ukrainian company, and its two conditions are cumulative: being the founder, a participant or the ultimate beneficial owner of a legal entity entered in the State register, and holding a share in the charter capital at least equal to the equivalent of EUR 100,000 at the official rate of the National Bank of Ukraine on the date of the contribution of the foreign investment.

The file for a temporary residence permit is lodged no later than fifteen working days before the end of the stay authorised in Ukraine. That period too is counted backwards, from the last day on which the person may lawfully be on the territory, and not from their arrival. Where the permit expires, the file for its exchange may be lodged up to the last day of its validity. These rules appear in the procedure approved by Cabinet of Ministers Resolution No. 322 of 25 April 2018, in force in its redaction of 10 May 2026.

The permanent residence permit follows another logic: it is not the sequel to a length of stay, but the sequel to an immigration permit. Law No. 2491-III of 7 June 2001 “On immigration”, in force in its redaction of 16 January 2026, grants that permit to the categories it defines, and provides that an immigration quota is set by the Cabinet of Ministers “in the event of a mass arrival of immigrants”, which makes it a conditional instrument and not a permanent quota. The law opens in particular the long-stay route and the investment route, both among the categories for which a quota may be set. The first covers persons falling within only some of the grounds of temporary stay, which the law designates exhaustively and among which are employment, international technical assistance and the supervision of a Ukrainian company, on condition that they have resided without interruption on Ukrainian territory under a temporary residence permit for the last five years. The second is the investment route: persons who have made a foreign investment in the Ukrainian economy, in convertible currency, of an amount of at least USD 100,000. That threshold and that currency are not those of the temporary residence permit for the supervision of a company: these are two distinct rules, in two distinct laws, and they are not to be conflated.

Two deadlines frame the application for a permanent residence permit, and they operate together. A person who has obtained an immigration permit has one year from the day that permit is issued in which to lodge their application. Within that window, the application must be lodged no later than fifteen working days before the expiry of the long-term visa for a person arriving from abroad, or before the expiry of the established period of stay or of temporary residence for a person already lawfully in Ukraine. The permanent residence permit is issued for ten years; it is drawn up for foreign nationals and stateless persons holding an immigration permit, under the procedure approved by Cabinet of Ministers Resolution No. 321 of 25 April 2018.

Registration on entry and the declaration of a place of residence are two different things. The registration of foreign nationals and stateless persons entering Ukraine is carried out at the border crossing points by the border guard bodies, and the entry made in the passport document or in the immigration card is valid throughout the territory, whatever the place of stay or of residence. The declaration or registration of the place of residence falls under another law, Law No. 1871-IX of 5 November 2021, in force in its redaction of 15 November 2024. It lays down two periods of 30 calendar days with two distinct starting points: a foreign national or stateless person residing lawfully, permanently or temporarily, on Ukrainian territory declares or registers their place of residence within 30 calendar days of their arrival at the new place of residence; and they declare or register their place of residence, and that of children under fourteen of whom they are the parent or legal representative, within 30 calendar days of receiving the permanent residence permit or the temporary residence permit, or after removal from the place of residence previously declared or registered.

A foreign national and a stateless person staying lawfully on Ukrainian territory are required to hold a valid passport document. In the event of the loss or exchange of the passport document, as in the event of the loss or theft of the permanent residence permit or of the temporary residence permit, the person informs the State Migration Service in writing within three working days. The host party has obligations of its own: to take the measures needed for foreign nationals and stateless persons to lodge in good time their applications for the documents opening the right to reside or to stay in Ukraine, to report the end of the grounds for the stay or the temporary residence of the persons it has invited or is hosting, and to bear the costs connected with their stay and their departure. Texts consulted on 30 August 2026.

The rule is laid down by the first part of article 42 of Law No. 5067-VI of 5 July 2012 “On the employment of the population”, in force in its redaction of 12 September 2025. The subject of the sentence is the employer: employers have the right to employ foreign nationals and stateless persons on Ukrainian territory on the basis of a permit issued by the territorial bodies of the central executive authority implementing State policy in the field of employment of the population and of labour migration. The instrument carries, throughout the law, the name of permit for the application of the labour of foreign nationals and stateless persons in Ukraine.

The second paragraph of that first part, added by Law No. 2623-IX of 21 September 2022, makes the issue and the extension of the permit, for the nationals of the States it designates, subject to agreement with the regional bodies of the Security Service of Ukraine. The States concerned are those the text itself designates.

The second part of the same article deals with the case of several employers and lays down the only exception attached to it. The labour of foreign nationals and stateless persons may be applied in different posts with one or several employers, two or more, on condition that the permit is obtained by each employer. It may be applied without a permit in a concurrent post with a single employer, if the term of the employment contract on that concurrent post does not exceed the term of the permit obtained for the principal place of work. The same employer and the term of the contract are conditions of that exception. The third part adds that a foreign national or a stateless person may combine the post defined by the permit with the post of a temporarily absent employee, on condition that the combination lasts no more than 60 calendar days per calendar year.

The sixth part enumerates the categories whose employment takes place without the permit provided for by that article. That enumeration is closed in its form, since it is introduced without an opening word, but its last point refers to other foreign nationals and stateless persons in the cases provided for by laws and by the international treaties ratified by the Verkhovna Rada. The class of exempt persons is therefore not closed by that article: it is its own enumeration that is.

Other parts of the same article complete the regime. The fifth part of article 42 provides that foreign nationals and stateless persons cannot be appointed to a post or carry on an activity where, under the legislation, appointment to that post or the carrying on of that activity is tied to Ukrainian citizenship, unless the international treaties ratified by the Verkhovna Rada provide otherwise. The fourth part states that foreign nationals and stateless persons have the right to carry on investment, foreign trade and other activities in Ukraine in accordance with the legislation. The seventh part opens a separate route: the attraction of highly qualified foreign specialists and workers whose need is felt by the national economy takes place on the grounds defined by the law on immigration, that is to say through the immigration permit.

The penalty falls on the employer. Article 53 of the same law provides that where an employer employs foreign nationals or stateless persons on the terms of an employment contract or of another contract without the permit for the application of labour, a fine is levied for each person, equal to twenty times the minimum wage in force at the time the infringement is established; and that where they are employed on terms other than those provided for by that permit, or by another employer, the fine is ten times the minimum wage for each person, on the same time reference. The point of reference is the moment the infringement is established, and not the moment the work began.

The permit is withdrawn, and that bears directly on the residence permit. The employer is required to apply to the territorial body for withdrawal of the permit where the employment contract or the gig contract concluded with the foreign national or stateless person has come to an end, where the contract concluded between the Ukrainian operator and the foreign operator under which the person had been posted has come to an end, or where the State Migration Service has recognised the person as a refugee, as being in need of complementary protection or as stateless. The withdrawal is notified by the territorial body, in particular to the territorial body of the State Migration Service. Texts consulted on 30 August 2026.

The regime is established by Law No. 1667-IX of 15 July 2021 “On stimulating the development of the digital economy in Ukraine”, in force in its redaction of 28 August 2025. Its article 2 states its purpose, its article 4 lays down the voluntary character of the acquisition of the status and the date on which the entry in the register takes effect, and its article 3 carries the twenty-five-year stability guarantee together with its exception, which removes from the guarantee legislative amendments touching defence, national security, public order and the environment. The twenty-five years run from the entry of the first resident in the register, and not from the entry of each company; the law does not state that date, which is not established.

Article 5 lays down the conditions of access. Its text closes them itself, since it requires the legal entity to meet all those requirements. The list of activities covered by its fourth part is, by contrast, not closed: it covers computer programming and computer consultancy, the publishing of video games and of other software, the supply of software products online, educational activity in the field of information technology, data processing and the activity related to it, with the exception of the supply of data processing and hosting infrastructure and of hosting services, as well as the activity of web portals, research and experimental development in the natural and technical sciences relating to information and communication technology, marketing campaigns and advertising services using software developed with the assistance of a resident, the activity of organisers of electronic sports competitions, of teams, of specialised computer centres and clubs and of studios broadcasting those competitions, the supply of services connected with the circulation of virtual assets, the cybersecurity of information and communication systems, the design and testing of robotic technologies and systems, and its last point refers to the other activities defined by the Cabinet of Ministers.

The consequences for the persons who work under that regime are laid down by the same law. The fourth part of its article 4 leaves the resident the choice between three instruments of engagement: the employment contract, the gig contract specific to the regime, and other civil-law or commercial contracts, including with sole traders. Articles 17 and 18 define the gig contract, its written or electronic form, its civil-law character, the grounds that bring it to an end and the notice periods. Article 19 deals with remuneration, which may be set in foreign currency. Article 21 deals with the time of performance and with the paid annual break. Articles 22 and 23 deal with insurance against temporary incapacity, with the break for pregnancy and childbirth, with the prohibition on the resident withdrawing unilaterally from the contract in those periods, and with the resident’s obligation to declare the conclusion of the gig contract to the authority responsible for administering the unified social contribution before performance begins, and then to calculate and pay that contribution for the gig specialist.

The personal tax treatment of the specialist is laid down by the Tax Code, and not by the Diia City law. The Code, in its redaction of 31 May 2026, defines the specialist of a Diia City resident as the gig specialist who carries out work or supplies services on the order and in the interest of the resident under a gig contract, and as the person who is in an employment relationship with it. The 5% rate is the one in point 167.2 of its article 167, and the provision attaching it to the specialists of a Diia City resident is point 170.14-1.2 of its article 170, point 167.2 not naming the regime. That point 170.14-1.2 enumerates the three kinds of income covered, excludes the Diia City resident that also holds Defence City resident status, and sets the starting point of the rate at the calendar month following that of the acquisition of the status. Point 170.14-1.3 carries the annual ceiling, its conversion rule and the obligation to declare the excess. Points 170.14-1.5 and 170.14-1.6 carry the consequence of the monthly conditions on average remuneration and on headcount not being met, and the accommodation enjoyed by companies that entered under the derogation.

Point 170.14 of the same Code deals with an entirely different subject, the minimum tax liability on agricultural land: only point 170.14-1 concerns Diia City. The sub-point that provided for a reduced military levy for the specialists of a Diia City resident was removed by Law No. 4113-IX of 4 December 2024; the ordinary rate therefore applies to them, and a source predating that date which states 1.5% for them describes a state of the law that has been repealed. The unified social contribution owed by a Diia City resident follows a rule of its own, laid down by Law No. 2464-VI of 8 July 2010, in its redaction of 26 January 2026, under the same monthly conditions on average remuneration and on headcount and with the same exclusion of Defence City residents. Texts consulted on 30 August 2026.

These rules are read in the Tax Code of Ukraine, Law No. 2755-VI of 2 December 2010, in its redaction of 31 May 2026, the one in force on the day of the reading. The tax residence of an individual is defined at point 14.1.213 of its article 14, and it is a sequence of tests applied in a determined order. A resident individual is a person who has their place of residence in Ukraine. If they also have a place of residence in a foreign State, they are deemed resident if they have their place of permanent residence in Ukraine. If they also have a place of permanent residence in a foreign State, they are deemed resident if they have closer personal or economic ties, the centre of vital interests, in Ukraine. If the State in which the person has their centre of vital interests cannot be determined, or if the person has no place of permanent residence in any State, they are deemed resident if they stay in Ukraine for at least 183 days, the day of arrival and the day of departure included, during the period or periods of the tax year. If the status still cannot be determined, the person is deemed resident if they hold Ukrainian nationality. For a stateless person not covered by the preceding limbs, the status is determined under the norms of international law.

The same point adds two rules of sufficiency, which are not degrees of that sequence. The place of permanent residence of the members of the person’s family, or their registration as a subject carrying on entrepreneurial activity, is a sufficient “but not exclusive” condition for locating the centre of vital interests. And the determination by the person themselves of their principal place of residence on Ukrainian territory, in the forms provided for by the Code, or their registration as a person carrying on independent activity, is a sufficient ground for regarding them as resident. The Code finally writes an express negative: acquiring the status of electronic resident is not a sufficient condition for locating the centre of vital interests of an individual.

Liable to the tax are the resident individual, who is taxable both on their Ukrainian-source income and on their foreign income, the non-resident individual, who is taxable on their Ukrainian-source income, and the tax agent. Point 167.1 of article 167 lays down the rate of 18% of the taxable base, except in the cases defined at points 167.2 to 167.5 of the same article, and it presents the enumeration of the income covered as open. Point 164.6 of article 164 lays down the salary base. In the tax year in which a foreign national acquires the status of resident of Ukraine, they file an annual declaration in which they state their Ukrainian-source income and their foreign income.

The military levy does not appear in the body of the income tax, but at point 16-1 of subsection 10 of section XX of the Code, that of the transitional provisions. Its text establishes it “on a temporary basis, until the entry into force of a decision of the Verkhovna Rada of Ukraine on the completion of the reform of the armed forces of Ukraine”. That anchor is not martial law. The payers are the persons covered by point 162.1, that is to say those of the income tax, together with two categories of single tax payers. For the former, the object of taxation is the one defined by article 163, the same as that of the income tax, and the rate is 5%. The Code separates those two quantities: its article 163 is entitled “object of taxation” and its article 164 “base of taxation”, the base, on which point 164.6 operates the reductions for salary; the text of the levy writes its rate as a percentage of the object of taxation. A rate of 1.5% appears in the same text, but it covers military personnel and the staff of the armed forces and of the other military formations constituted under the laws of Ukraine, on the monetary allowance and the other payments they receive on that basis: it is not the rate of a civilian employee.

The text carries two distinct anchors, and conflating them would be an error. For payers of the income tax, the Code provides that, from 1 January of the year following the third calendar year after the year in which the martial law introduced by Decree No. 64/2022 comes to an end or is lifted, the rate of the levy becomes 1.5%. For the single tax payers of the two categories covered, the levy is established from 1 January 2025 until 31 December of the third calendar year following the year in which martial law comes to an end or is lifted. Those two clauses are conditioned on an event that has not taken place.

The unified social contribution falls under another text, Law No. 2464-VI of 8 July 2010, in force in its redaction of 26 January 2026, whose article 8 provides that it does not form part of the tax system. Its article 4 designates the persons liable to it, first among them employers, and its article 7 lays down its base. On double taxation, this page does not establish the current state of any bilateral convention between Ukraine and another State, nor the treatment of the same income in that other State, and it puts forward no date for one. The Ukrainian rules stated here are therefore not the whole answer for a person who also has obligations in another State.

Texts consulted on 30 August 2026.