The State Tax Service (STS) of Ukraine has issued guidance on the taxation of insurance payments (insurance premiums/claims/indemnities) to non-residents within the scope of insurance or reinsurance contracts, including life insurance. While taxable Ukraine source income is generally subject to withholding tax at a rate of 15%, the following rates are provided for insurance payments:

• 0% on payments made for the benefit of non-resident individuals, as well as on payments under insurance contracts within the system of international "Green Card" agreements and under civil aviation passenger insurance contracts;
• 4% on payments made for the benefit of non-residents in respect of insured risks outside of Ukraine, except for the above;
• 0% on payments made under insurance or reinsurance contracts concluded directly with non-resident insurers and reinsurers whose financial soundness (stability) rating meets the requirements established by the National Commission for State Regulation of Financial Services Markets, as well as under contracts for compulsory civil liability insurance of nuclear installation operators for damage that may be caused by a nuclear incident; and
• 12% on payments in other cases.

The above rates are provided under sub-section 141.4.5 of Article 141 of the Ukraine Tax Code and apply for insurance payments made by residents, including non-residents conducting economic activity through a permanent establishment in Ukraine.