RULG - Ukrainian Legal Group

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Ukraine Ukraine Ukraine Ukraine Ukraine Ukraine

Olimpiysky Center

Suite 14, 11th floor

72 Velyka Vasylkivska Street

Kiev, 03150

Tel: +380 (44) 207-1060 / 61 / 62 / 63

Tel: +380 (44) 207-1064

4056 Mansion Drive, N.W.

Washington, D.C. 20007

Tel: +1 (202) 338-1182

Fax: +1 (202) 338-4237


Corporate income taxation
Corporate Tax 23% (in 2011)
21% (in 2012)
19% (in 2013)
16% (since 2014)
Dividends currently 23%, will gradually decrease to 16% (by 2014)
Participation Exemption
  • Available for dividends from residents and controlled non-offshore non-residents
Capital gains N/A
Deduction of Interests
1-st group of the Foreign Currencies Classification (USD, Euro, British pounds, Swiss franks, Japanese yena):
  • for fixed interest rate (depends on loans’period)
  • for floating interest rate

2-nd or 3-rd group of the Foreign Currencies (CIS currencies, Hong Kong dollars, Singapore dollars)

9,8 / 10 / 11 %
LIBOR for 3 m. deposits in USD + 750 b.p.

20 %

(on WTG AVG)
Thin Capitalization Rule

Applicable to the controlled (over 50%) debtors


Straight-line, reducing balance, accelerated reducing balance, cumulative, productive

Transfer Pricing Rules
Methods: Comparable Market Prices; Resale Price; Cost plus; Transaction Net Margin Method; Profit Split Method     
New rules - 2013
Loss carried forward
Loss carried backward

Special rules for a number of operations (securities and financial instruments, payments in a foreign currency, payments with related persons, dividends, debt claims and liabilities, alienation of property, leasing, etc.)


Tax consolidation Yes
Withholding taxation
Dividends 15%
Income from sale of shares, royalties, interests, certain other incomes 15%
Freight 6%
Incomes from interest-free bonds 16%
Interests charged on public securities 0%
Insurance fees 0-12%
Fees for the production and/or distribution of a resident’s advertising by non-resident 20% (payable by the resident)

Double Tax Treaty Network (over 60 DTTs): reduction /elimination of WTH taxation /refund of extra tax   

Personal Income tax

General rate
If an individual’s income exceeds 10 minimal wages
Same tax rate for residents and non-residents

Shareholder-Relief-System / Tax rate for Dividends
Inheritance tax
Depends on the object to be inherited, kinship and residency

0% / 5% / 15%

Real Estate Transfer Taxes / Duty 1%
of transaction value
Value Added Tax
Standard rate

20% (in 2011-2013),

17% (in 2014)
Reduced rate N/A
General VAT payer registration threshold – UAH 300,000 (approx EUR 26,390)

Tax on Land


Tax base is cadastral value of land

Rates vary and depend on the functional use of land
Tax on Real Estate (takes effect on 1 January 2012)
Tax base is minimum salary established subject to living area of real estate

On used natural resources (oil, gas, coal, peat, ores, etc.)

On alcohol, tobaccos, petroleum, liquefied gas, motor cars, car bodies, trailers and semitrailers, motorcycles 
Single Social Contribution to the Pension Fund
(on gross salary)
(on top of gross salary depending on the type of business activity)
Incentives for Investors

Property imported as a contribution to a company's authorized capital is exempt from custom duty
(except for goods intended for sale or own consumption)

Special (simplified) tax regime
Available for small businesses / individual entrepreneurs
  • CIT of annual revenues not including excise taxes (VAT payable)
  • CIT of annual revenues, except for excise taxes, ( VAT not payable)


Advance (binding) tax rulings N/A
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