Revenue eBrief No. 098/24

26 March 2024

Tax treatment of Ukrainian citizens who work remotely in the State for Ukrainian employers

On 14 April 2022, Revenue issued eBrief No. 090/22. This eBrief outlined Revenue's concessional treatments with regard to Ukrainians who:

• came to the State as a result of the war in their country, and
• continued to be employed by their Ukrainian employer while performing the duties of their employment remotely from Ireland.

The concession provided that in relation to Ukrainian employment income:

• these Irish-based employees of Ukrainian employers were treated as not being liable to Irish income tax and USC on Ukrainian employment income that was attributable to the performance of duties in the State, and
• the Ukrainian employers were not required to operate the PAYE system on such employment income.

This concession applied solely to employment income paid to the Irish-based employees by their Ukrainian employer.

Revenue also disregarded the presence of these employees in Ireland for Corporation Tax purposes in respect of any company resident in Ukraine, where the employee, director, service provider or agent would have continued to be present in Ukraine but for the war there.

On 7 February 2023, Revenue confirmed in eBrief No. 028/23 that the concessional treatments outlined above would also apply for the tax year 2023.

Extension of concession (Tax year 2024)

Given the continuation of the war in Ukraine and the ongoing humanitarian crisis, Revenue confirms that the concessional treatments as set out above will continue to apply for the tax year 2024, subject to the qualifying conditions which are outlined in eBrief No. 090/22.

Any individual or relevant entity that avails of these concessional treatments should continue to retain evidence to support compliance with the qualifying conditions.

These concessional treatments will cease with effect from 1 January 2025. From this date, the Irish-based employee and the Ukrainian employer will be required to comply with the Irish tax requirements arising from the exercise of the duties of the Ukrainian employment in Ireland.