Portugal vs Ukraine: the two tax systems, side by side (2026)

Who counts you as resident

Ukraine’s Tax Code (art. 14.1.213) treats you as resident if your home is in Ukraine; with a home in both countries it looks at your permanent home, then your centre of vital interests — and it says outright that the place where your family lives, or your registration as a private entrepreneur (FOP), is enough to fix that centre. Failing all that, 183 days; failing that, Ukrainian citizenship. Portugal makes you resident after 183 days in any twelve months, or from the first day you keep a home here as your habitual residence (IRS Code, art. 16.º).

So a family that moved to Lisbon in 2022 with a temporary-protection certificate is resident in Portugal under Portuguese law, and may still be resident in Ukraine under Ukrainian law. The convention of 9 February 2000 breaks the tie (art. 4): permanent home, then centre of vital interests, then habitual abode, then nationality. A rented flat in Portugal with the children in a Portuguese school usually settles it for Portugal; a spouse and a business left in Kyiv can pull the other way. The answer matters because the residence state taxes worldwide income and the other only what arises there.

• 18 % + 5 % — Ukrainian personal income tax and military levy, flat on salaries, freelance income, rents and most other income
• 12,5 % to 48 % — Portuguese IRS by bracket after a 4 587 € deduction on salaries and pensions; solidarity 2,5 % above 80 000 €
• 22 % — Ukrainian single social contribution, paid by the employer only, on salary up to 20 minimum wages; Portugal 11 % employee + 23,75 % employer
• 15 % / 10 % — 10 % — 10 % — treaty ceilings on dividends, interest and royalties; pensions and salaries follow residence and place of work

Income tax on people

A Kyiv salary of UAH 150 000 a month (1,8 million a year, about 35 100 € at the National Bank’s rate of 51,24 UAH per euro on 18 September 2026) costs 414 000 UAH of tax and levy in Ukraine — 23 %, whatever the level. The same 35 100 € earned in Portugal costs about 6 450 € of IRS (18,4 %) plus 3 864 € of employee contributions: 29,4 % together, but with a state pension, unemployment and sickness cover accruing. At 60 000 € the Portuguese share rises to about 15 400 € of IRS and 6 600 € of contributions, 36,6 %, while Ukraine stays at 23 %. Ukraine’s system is cheap and flat; Portugal’s is progressive and comes with a welfare state attached.

Companies, VAT and the single tax

Ukraine’s group-3 single tax is the reason so many Ukrainian IT contractors pay 5 % — and the reason many of them are surprised in Portugal, where the same invoices are Portuguese business income once they live here. The NHR and IFICI page works through that case.

Social security

Unlike most non-EU countries, Ukraine has a social-security convention with Portugal (signed 7 July 2009, in force since 1 March 2012): you contribute in the country where you work, whoever the employer is (art. 8); a worker posted by a Ukrainian company stays in the Ukrainian system for up to 12 months, extendable once (art. 9); insurance periods in both countries are added together to open a pension right (art. 15); and pensions are paid to a resident of the other country without reduction (art. 6). A Ukrainian who worked twenty years in Kyiv and ten in Lisbon can therefore claim both pensions, each pro rata.

The convention of 2000

Signed in Lisbon on 9 February 2000, approved by Resolução da Assembleia da República n.º 15/2002, in force since 11 March 2002 and applied since 1 January 2003. What it fixes:

• Salaries (art. 15): taxed where the work is physically done. A Portuguese resident working remotely from Portugal for a Ukrainian employer is taxable in Portugal only; Ukraine may tax only work done on Ukrainian soil, and even that stays with Portugal if the stay is under 183 days in twelve months and the employer is not Ukrainian.
• Freelance and professional income (art. 14): residence state only, unless you keep a fixed base in the other country.
• Dividends (art. 10): 15 %, or 10 % for a company holding 25 % for two years. Interest (art. 11) 10 %, state bonds exempt. Royalties (art. 12) 10 %.
• Pensions (art. 18): residence state only. Government pensions (art. 19): the paying state, unless the pensioner is resident and national of the other.
• Property (art. 6 and 13): taxed where the property stands; gains on shares of property-rich companies likewise; other gains in the residence state.
• Other income (art. 22): residence state only.
• Relief (art. 24): both countries credit the other’s tax, up to their own tax on that income. Ukraine’s Tax Code adds the mechanics: a Ukrainian resident claims the credit in the annual return (art. 170.11.2); Ukrainian payers apply treaty rates at source on a certificate of Portuguese residence (art. 103.4).

The military levy was created after the treaty was signed; whether it is a tax “of identical or similar nature” under art. 2 n.º 4, and so creditable in Portugal, is a point to argue case by case — we do not assume it.

Property

Buying in Ukraine costs 1 % state duty at the notary and 1 % pension-fund duty from the buyer; holding costs a municipal property tax of up to 1,5 % of the minimum wage per square metre above 60 m² for a flat or 120 m² for a house (up to 129,71 UAH per m² in 2026); selling one home a year held over three years is tax-free. Portugal charges IMT by bracket and 0,8 % stamp duty on purchase, IMI of 0,3–0,45 % of the tax value every year, 25 % on rents and tax on half the gain at sale. The property comparison has the tables and what happens to the flat in Kyiv.

Money

Ukraine still runs wartime exchange controls: National Bank Resolution No. 18 of 24 February 2022 prohibits transfers out of Ukraine except through listed channels, widened again on 11 August 2026 (200 000 UAH a month for payments and rent abroad from hryvnia accounts, 500 000 UAH a month for accommodation from foreign-currency accounts, 200 000 UAH a day of cash from FX accounts). Portugal has no exchange controls at all, but a resident must list foreign bank accounts in the annual return and declare cash of 10 000 € or more at the EU border. Detail on the transfer page.

Special regimes and the war

The old NHR regime closed on 1 January 2024; IFICI (20 % for ten years on listed activities, foreign income exempt) is open to people not resident here in the previous five years — which excludes most Ukrainians who arrived in 2022, but not a newcomer of 2026. The war changes on the Ukrainian side — the levy at 5 %, the single-tax levy, the bank surcharge, the extension of EU temporary protection to 4 March 2028 — are on the war tax changes page.

Settling the file

Questions from Ukrainian clients