PARLIAMENTARY WRITTEN QUESTION
Refugees: Ukraine (12 December 2022)

The UK and the Ukraine have been signatories to a comprehensive Double Taxation treaty since 1993, which is available on GOV.UK:

https://www.gov.uk/government/publications/ukraine-tax-treaties

This treaty specifies how the two countries should tax income paid between the two countries with a view to avoiding double taxation.

A key concept for interpreting the treaty is the residence of the person receiving the income. A Ukrainian national living in the UK may be resident in either the UK or Ukraine under each country’s domestic legislation, or they may be resident in both. If the recipient is resident in both countries, the treaty sets out several tests to establish one single ‘treaty residence’. These tests consider all the individual’s facts and circumstances.

For pension income sourced in Ukraine, this will only be taxed in the country where the recipient is resident under the treaty, which could either be the UK or Ukraine depending on the circumstances.

The treatment of other types of income will vary, as set out in the treaty. HMRC has provided bespoke guidance (translated into Ukrainian) for situations where Ukrainians maintain their employment in Ukraine while present in the UK. This is also available on Gov.uk:

https://www.gov.uk/guidance/paying-taxes-in-the-uk-if-you-work-for-an-employer-based-in-ukraine