Türkiye–Ukraine double taxation avoidance agreement

This page is for Turkish citizens with income between Türkiye and Ukraine: those working in Ukraine and renting out a home in Türkiye, those receiving dividends from a Turkish company, retirees living in Ukraine, and those doing business between the two countries. The agreement prevents the same income from being fully taxed in both countries and determines which country may tax which income and at what rate. The agreement was amended by a protocol signed in 2017; the new rates have applied since 2021.

• Original agreement: "Agreement Between the Government of the Republic of Türkiye and the Government of Ukraine for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital"
  • Signed: 27 November 1996
  • Official Gazette: 22 April 1998, issue 23321
  • Entry into force: 29 April 1998
• Amending protocol:
  • Signed: 9 October 2017, Kyiv
  • Ukrainian approval: Law No. 106-IX dated 18 September 2019
  • Turkish approval: Presidential Decision No. 3012, Official Gazette 25 September 2020
  • Entry into force for Ukraine: 30 November 2020
• The protocol applies to amounts paid after 1 January 2021 for withholding taxes, and to tax years beginning on or after 1 January 2021 for other taxes.
• According to the protocol, the taxes covered by the agreement are:
  • In Ukraine: corporate income tax (податок на прибуток підприємств) and personal income tax
  • In Türkiye: income tax and corporate income tax

• To benefit from the agreement, you must be a resident of one of the two countries (Articles 1 and 4).
• If you are considered a resident under the laws of both countries, the following criteria are examined in order (Article 4):
  1. Permanent home: if you have a permanent home in only one country, you are a resident of that country.
  2. Centre of vital interests: if you have homes in both countries, the country with which your personal and economic relations are closer.
  3. Habitual abode: if this cannot be determined, the country where your habitual abode is located.
  4. Citizenship: if the issue still cannot be resolved, the country whose citizen you are.
  5. If necessary, the competent authorities of the two countries decide by mutual agreement.
• Turkish side: According to the Revenue Administration, Turkish citizens who have lived abroad for more than six months after obtaining a work or residence permit are subject to limited tax liability with respect to income earned in Türkiye (Income Tax General Communiqué No. 210). Those abroad on behalf of public institutions or companies headquartered in Türkiye are excluded from this rule.
• Ukrainian side: see U8.1 for residence criteria.

• Your salary may be taxed in the country where you perform the work. If you work in Ukraine, Ukraine may tax it.
• 183-day exception: when a resident of one country works in the other country, the salary is taxed only in the country of residence if all three of the following conditions are met:
  1. staying in the other country for a total period not exceeding 183 days in any 12-month period beginning or ending in the relevant fiscal year
  2. the remuneration is paid by, or on behalf of, an employer who is not a resident of that country
  3. the remuneration is not borne by a permanent establishment of the employer in that country
• Remuneration of employees working on construction sites, construction, assembly and installation projects, and remuneration of employees working on ships, aircraft or land vehicles operated in international traffic, is not taxed in the other country (Protocol Article 8).
• A construction site or assembly project creates a permanent establishment in that country if it exceeds 12 months (Article 5).

• These types of income may be taxed in the recipient's country of residence. The source country may also tax them, but its tax may not exceed the following rates:
• Dividends (Protocol Article 5):
  • 10%: if the beneficial owner is a company that directly or indirectly owns at least 25% of the capital of the company paying the dividends (excluding partnerships)
  • 15%: in all other cases
• Interest (Protocol Article 6): 10%. The following interest is taxable only in the recipient's country:
  • interest paid to the state, local authorities or the central bank
  • interest paid by the state or a local authority
  • interest on loans granted, guaranteed or insured by the state
• Royalties (Protocol Article 7): 10%.
• For comparison: Ukraine generally withholds 15% tax under domestic law on payments made to non-residents (Tax Code Article 141.4.2). A certificate of residence is required to apply the treaty rate (see below).

• Income from immovable property, including rent, may be taxed in the country where the property is located (Article 6).
• Gains from the sale of immovable property may also be taxed in the country where the property is located (Article 13).
• Capital gains from the sale of shares and similar securities are generally taxed in the seller's country of residence. If the period between acquisition and sale does not exceed one year, the source country may also tax the gain (Article 13/4).
• Example: You live in Ukraine and rent out your home in Türkiye.
  • Türkiye may tax this rent. As a limited taxpayer, you declare your rental income in Türkiye.
  • According to the Revenue Administration guide, the residential rental income exemption is TRY 47,000 for 2025 and TRY 58,000 for 2026. The return for 2025 income was filed between 1 and 31 March 2026.
  • If you are a resident of Ukraine, you also report this rent on your Ukrainian return. You credit the tax paid in Türkiye against your Ukrainian tax (Article 23; see U8.1).

• Pensions: pensions paid in consideration of past employment are taxable only in the recipient's country of residence (Article 18/1).
• Social security payments: pensions and regular payments made under the social security system of a country are taxable only in that country (Article 18/3). For example, a pension you receive under Türkiye's social security system is taxable only in Türkiye.
• Students and trainees: payments received by a student who is present in the other country solely for education, from sources outside that country, for maintenance and education are not taxed in that country (Article 20/1).
• Teachers: remuneration paid from outside the country to persons who come for teaching or research in the public interest for a period not exceeding two years is exempt (Article 20/2).

• Credit method: when you earn income that may be taxed in the other country, your country of residence deducts the tax you paid in the other country from its own tax.
• The credit may not exceed the amount of your own tax attributable to that income.
• If income may be taxed only in the other country, your country of residence may include that income in the tax base but must deduct the tax attributable to it.
• For the documents and procedure required for a credit in Ukraine, see U8.1.

• If you are receiving a payment from Ukraine: the payer applies the lower treaty rate only after receiving a document showing that you are a resident of Türkiye. The document is issued by the Turkish competent authority and must be certified and translated into Ukrainian (Tax Code Articles 103.4–103.5).
• Certificate of residence for residents of Türkiye: under the Revenue Administration's Circular No. ÇVÖA/2013-1, the certificate is issued by the Tax Office Directorates (Ankara, Antalya, Bursa, Istanbul, Izmir, Kocaeli and Trabzon), the Large Taxpayers Tax Office Directorate and the Revenue Administration.
  • Full-liability Turkish citizens apply using the sample petition attached to the circular (ANNEX 1).
  • The application procedure may have changed; check the latest information with the Revenue Administration before applying.
• Certificate of residence for residents of Ukraine (Diia service No. 00401):
  • The application is submitted to the Tax Service office in the province where you are registered or to the Kyiv office. If you are temporarily elsewhere or have no permanent address, you may apply to any office.
  • The application may be submitted in person, by registered mail or through the Tax Service's electronic cabinet.
  • Free of charge; processing time is 10 calendar days. The certificate is issued in paper or electronic form.
  • If you submit a special form of a foreign country, such as the Revenue Administration form, with a Ukrainian translation, the Tax Service certifies the form with a signature and stamp.
• When providing Türkiye with a Ukrainian certificate of residence: the original certificate and a Turkish translation notarized or certified by a Turkish consulate are submitted to the tax office or the person making the tax withholding. If the certificate is not provided, Turkish domestic law applies instead of the agreement.

• The protocol renewed the agreement's exchange-of-information article (Article 26). The tax administrations of the two countries provide each other with information that may be relevant for applying the taxes.
• A country may not refuse to provide information solely because it is held by a bank.
• The protocol added Article 26A: the two countries assist each other in the collection of tax debts. A tax debt accumulated in one country may, at that country's request, also be collected in the other country.

• If you believe that an action by one country has resulted in taxation contrary to the agreement, you may refer the matter to the competent authority of your country of residence, independently of the remedies available under domestic law.
• The application must be submitted within the periods specified in the countries' domestic laws.
• If the competent authority considers the objection justified but cannot resolve it alone, it attempts to reach an agreement with the competent authority of the other country. Consult a tax professional or lawyer regarding your specific circumstances.

• Looking at the old rates in the 1998 text. The provisions on dividends, interest and royalties have applied according to the protocol text since 2021.
• Expecting a lower rate without providing the Ukrainian payer with a Turkish certificate of residence.
• Misunderstanding the 183-day exception: it does not apply if you receive a salary from an employer in Ukraine.
• Failing to declare rental income from Türkiye in Türkiye because it was taxed in Ukraine, or vice versa.
• Assuming that a tax debt will not be pursued in the other country. The protocol introduced assistance in collection.

• Since when has the agreement applied at these rates? The protocol entered into force for Ukraine on 30 November 2020. The new provisions have applied since 1 January 2021.
• If I receive dividends from my company in Ukraine in Türkiye, how much tax will be withheld? The treaty ceiling is 10% if you are a company owning at least 25% of the company, and 15% in other cases. A certificate of residence must be provided for this purpose.
• Will my pension from Türkiye be taxed in Ukraine? A pension paid under Türkiye's social security system is taxable only in Türkiye (Article 18/3).
• I work in Ukraine; will I also pay tax in Türkiye? If you have lived abroad for more than six months with a work or residence permit, you have limited tax liability in Türkiye only for your income earned in Türkiye.
• Does the Ukrainian certificate of residence cost anything? No. The Tax Service issues it free of charge within 10 calendar days.

• Revenue Administration – Turkish text of the Türkiye–Ukraine agreement (PDF)
• Verkhovna Rada of Ukraine – Amending protocol (full text in Ukrainian)
• Revenue Administration – List of double taxation agreements in force (PDF)
• Revenue Administration – Certificate of residence circular and sample petitions (ÇVÖA/2013-1)
• Revenue Administration – Rental income guide for limited taxpayers (2026, PDF)
• Diia guide – Ukrainian tax residence certificate (No. 00401)