Ukraine's wartime tax changes and what they mean for Ukrainians in Portugal

What changed in Ukraine, and when

The levy is a separate charge with the same base as personal income tax, so the effective flat rate on a Ukrainian salary or freelance fee is 23 % — 18 % tax plus 5 % levy — withheld by the employer or tax agent, and a group-3 entrepreneur’s 5 % single tax has become 6 %. Ukraine did not raise its main rates or introduce brackets; it added the levy and left the structure alone.

• 23 % — Ukrainian tax plus levy on salaries and most income since 1 December 2024
• 6 % — group-3 single tax plus levy on turnover; 864,70 UAH a month of levy for groups 1, 2 and 4 in 2026
• 25 % corporate tax for financial institutions from 2025; 50 % on banks for 2024
• 4 March 2028 — EU temporary protection now runs to this date

Temporary protection: the European and Portuguese side

The Council extended temporary protection for people displaced from Ukraine to 4 March 2028 (Implementing Decision (EU) 2026/1912 of 30 July 2026, applying from 5 March 2027). The same decision adds a condition for new grants from 31 July 2026: protection is given only to those who satisfy their military obligations in Ukraine, on proof where applicable — people already protected on 30 July 2026 and keeping their status are not affected. The Council’s recommendation of 16 September 2025 asks member states to move people towards other legal statuses and to prepare voluntary return when the situation allows.

In Portugal the status rests on Lei n.º 67/2003 and is managed by AIMA. The certificate is a residence title that assigns the tax number, the social security number and the health number in one step; the application runs on the SEFforUkraine platform. AIMA’s own answers on the two questions clients ask most: a beneficiary who leaves for Ukraine or another state must ask AIMA to cancel the status by e-mail, and a beneficiary may switch to another residence regime — but must renounce temporary protection at the counter, because two statuses cannot be held at once.

What it means for a Ukrainian living in Portugal

Residence first. The levy and the 18 % apply to Ukrainian residents on worldwide income and to non-residents on Ukrainian-source income (Tax Code, art. 162.1). Whether you are still a Ukrainian resident after three years in Portugal is decided by the Tax Code’s own test (home, centre of vital interests, 183 days, citizenship — art. 14.1.213) and, where both countries claim you, by article 4 of the 2000 convention. Most families settled here with a lease and children in school are Portuguese residents under that test, and Ukrainian non-residents.

Salaries and fees. For a Portuguese resident working from Portugal, the treaty gives the salary to Portugal alone (art. 15); a Ukrainian employer that keeps withholding 23 % is withholding tax the treaty does not allow, and Portugal will not credit it (IRS Code, art. 81.º n.º 2). The remedy is a certificate of Portuguese residence handed to the employer, which Ukrainian law accepts as the basis for applying the treaty at source (art. 103.4). The NHR and IFICI page has the full table.

Income Ukraine keeps. Rent from a Kyiv flat and dividends from a Ukrainian company remain taxable in Ukraine (18 % + 5 % on rent; 5 % or 9 % plus the levy on dividends, within the treaty’s 15 %). Portugal taxes them too and credits the Ukrainian income tax up to its own; whether the 5 % levy counts as a creditable “identical or similar” tax under art. 2 n.º 4 of the convention is a question we argue on the facts, not assume.

Contributions. Ukraine’s single social contribution — 22 %, employer only, on salary up to 20 minimum wages (172 940 UAH a month in 2026) — has not changed with the war. A Ukrainian employee of a Portuguese company pays 11 % with 23,75 % from the employer. The two countries do have a social-security convention — signed on 7 July 2009, in force since 1 March 2012 — under which you contribute where you work (art. 8), a worker posted by a Ukrainian employer stays in the Ukrainian system for up to 12 months, extendable once (art. 9), insurance periods in both countries are added together to qualify for a pension (art. 15), and pensions are paid into the other country without reduction (art. 6).

After the war: what the law already says

The 5 % levy on individuals lasts until 1 January of the year after the third calendar year following the year martial law ends — three full years of the higher rate after the war. The single-tax levy runs “from 1 January 2025 to 31 December of the third calendar year after” that year. The 25 % financial-institution rate has no sunset. EU temporary protection ends on 4 March 2028 unless extended again, or earlier if the Council finds a sustainable ceasefire allows return (recital 23 of the 2026 decision). Nothing in Portuguese tax law changes when the war ends: a resident is taxed as a resident, protection or not.

Steps

Questions