Departure return
Under TCU 179.3, a resident moving abroad permanently files a property and income return no later than 60 calendar days before leaving. The STS reviews it within 30 days and issues a tax clearance certificate (TCU 179.12).
No advance ruling
In case No. 757/50930/23-ц (May 12, 2026), Ukraine's Supreme Court declined to establish non-residency without an actual tax dispute. Status is assessed in audits and challenged decisions.
You should also take into account how Ukrainian law treats residency in the year of departure — this article does not cover it in detail.
Evidence to keep
- a residency certificate from your new country;
- lease or purchase documents abroad;
- family relocation and schooling;
- employment or business abroad;
- closure of your FOP, if consistent with the facts;
- border-crossing records.
CFC angle
The STS has said a CFC report is still due for a year in which you disposed of your interest. A non-resident is not a controlling person for periods of non-residency.
Read more in the guide. Related: Residency certificate, CFC basics.
