Tax registration of non-residents in Ukraine: grounds, deadlines and documents

Updated: November 2026

A foreign company may never set up a legal entity in Ukraine and still be required to register with the Ukrainian tax authority. The obligation arises from specific actions: opening a representative office, buying real estate, opening a bank account or acquiring shares in a Ukrainian company. Non-residents usually learn about it in practice, when a bank refuses to open an account, a notary declines to certify a contract or a tax audit ends with a penalty.

Four grounds for registration

Under paragraph 64.5 of Article 64 of the Tax Code of Ukraine (in Ukrainian) and the Procedure for registration of taxpayers approved by Order of the Ministry of Finance of Ukraine No. 1588 of 9 December 2011 (in Ukrainian), a non-resident (foreign company or organisation) must register with the tax authority if it:

operates in Ukraine through a separate subdivision, including a permanent establishment;
acquires real estate or property rights to real estate in Ukraine;
opens an account with a Ukrainian bank, another financial institution or a non-bank payment service provider, or an e-wallet under Article 64 of the Law of Ukraine “On Payment Services” (in Ukrainian). Correspondent accounts of non-resident banks are an exception;
acquires an investment asset (shares or corporate rights in a Ukrainian company) from another non-resident that has no permanent establishment in Ukraine.

Deadlines and where to file

The non-resident is registered on the basis of whichever event occurs first, no later than the next working day after the application is received.

The application must be filed:

separate subdivision — within 10 days after accreditation (registration) of the subdivision, with the tax authority at its location;
real estate — before acquiring the property or property rights, with the tax authority at the location of the property;
account or e-wallet — before opening the account, with the tax authority at the location of the bank or other institution;
investment asset — before the first payment for the asset, with the tax authority at the location of the Ukrainian company whose shares are acquired.

For three of these grounds, registration is a precondition for the transaction, not a formality afterwards. A bank will not open an account, and a real estate or share deal cannot be completed, without the non-resident’s tax number. Note that the investment asset ground applies only where the shares are sold by another non-resident without a permanent establishment. If the seller is a Ukrainian resident, no registration is required on this ground.

Registration is not the same as corporate income tax registration

Registration as such does not make a non-resident a corporate income tax payer. Separate registration is required in cases specified by the Tax Code, in particular where the non-resident:

carries on business through a permanent establishment;
has its place of effective management in Ukraine;
pays income and withholds tax.

Since 2021, the corporate income tax payer is the non-resident itself, not its permanent establishment. The permanent establishment is registered as a separate subdivision, and the non-resident and the subdivision file two applications at the same time.

A separate case is foreign suppliers of electronic services to individuals in Ukraine. They register as VAT payers under a simplified procedure under Article 208¹ of the Tax Code of Ukraine.

Documents

Registration requires an application in form No. 1-OPN (Annex 6 to Procedure No. 1588), together with copies of:

an extract from the trade, banking or other register of the country of incorporation, apostilled or legalised, with a notarised Ukrainian translation;
a document confirming the non-resident’s identification number in the country of incorporation, if it is not shown in the extract;
a document confirming the authority of the non-resident’s representative, legalised as required. The power of attorney should expressly cover actions relating to tax registration;
for a separate subdivision, documents on its registration (accreditation) in Ukraine.

Documents may be filed in person by a representative, by post or electronically. If filed by post, copies must be notarised.

Registration is confirmed by a certificate in form No. 34-OPP. The non-resident is assigned a nine-digit tax number beginning with “88”. Subsequent changes to the non-resident’s details, such as its name, address or director, must be reported to the tax authority.

Representative office: registration first, then tax registration

A representative office of a foreign company is first registered and only then registered with the tax authority. Since 3 September 2024, under Law of Ukraine No. 3257-IX of 7 August 2023, representative offices are registered exclusively by the Ministry of Justice of Ukraine. Certificates previously issued by the Ministry of Economy remain valid, but all new registrations and changes go through the Ministry of Justice. More details are in the article on registration of a foreign representative office in Ukraine.

Liability

Operating through a separate subdivision, including a permanent establishment, without tax registration is subject to a fine of UAH 100,000 (paragraph 117.4 of Article 117 of the Tax Code of Ukraine, in Ukrainian).
Such a breach is also a ground for administrative seizure of property (subparagraph 94.2.9 of Article 94 of the Tax Code of Ukraine).
A non-resident that has missed the deadline is not released from the obligation to register.

Our services

Analysing the non-resident’s position: whether there is an obligation to register, to register as a corporate income tax or VAT payer, and the risk of a permanent establishment.
Preparing the application in form No. 1-OPN, arranging legalisation and translation of documents, filing with the tax authority and obtaining the registration certificate.
Registering a foreign company’s representative office with the Ministry of Justice, followed by tax registration of the non-resident and the representative office.
Supporting the opening of a non-resident’s account with a Ukrainian bank.
Supporting non-residents’ transactions involving real estate and corporate rights in Ukrainian companies.
Defending clients against penalties and other sanctions for breaches of registration rules, in administrative and court proceedings.