Almost every enquiry we receive on this topic starts the same way. Someone has decided to register abroad, the paperwork is nearly ready, and then a question arrives: how do I actually get the share capital across?
The honest answer surprises people. In most cases, you cannot simply transfer it. Not because the amount is large, and not because anything is wrong with the plan, but because sending money abroad for the purpose of acquiring shares in a company outside the country is one of the categories the National Bank has kept closed since February 2022.
That does not end the project. It changes how the project gets funded, and knowing this before you sign anything saves a great deal of frustration.
A word on dates before the detail. The National Bank has amended this framework repeatedly, including in January, April, June and August 2026. Everything below states the position as at 11 August 2026 and should be re-checked before you act on it.
The Rule That Governs Everything Else
Start with the general principle, because everything downstream follows from it. Under National Bank Resolution No. 18 of 24 February 2022, cross-border transfers out of the country are prohibited unless a specific permission exists. Not restricted. Prohibited by default, with a growing list of exceptions carved out on top.
Since 2022 the regulator has dismantled a good deal of the original framework. Payments for imported works and services performed after 23 February 2021 are open. Leasing and rental payments went through. Dividend repatriation returned in stages. Several new mechanisms arrived during 2025 and early 2026.
What has not reopened is outbound investment by residents.
What is permitted today, broadly
| Category | Position |
| Payment for imported goods, works and services | Permitted, subject to settlement deadlines |
| Dividends to non-resident shareholders | Permitted for profits accrued from 1 January 2023, capped at the equivalent of EUR 1 million per month, and subject to the issuer having been registered for at least 12 months and the investor having held the corporate rights for at least six months |
| Servicing external loans | Permitted under conditions, with a maximum interest rate of 12% per annum on new borrowings |
| Leasing and rental payments abroad | Permitted |
| Acquiring shares or contributing capital abroad | Not among the permitted categories, and therefore caught by the general prohibition |
| Individual cross-border P2P and quasi-cash | Capped at the equivalent of UAH 100,000 per month, reduced to UAH 50,000 for higher-risk clients, with a limit on the number of operations |
The three special limits
Three additional mechanisms now sit alongside the general list, and each works the same way: money that came in creates headroom for money going out.
- The investment limit, running since 12 May 2025, matches the foreign currency that overseas investors put into a resident company’s charter capital.
- The donation limit, from 7 August 2025, matches amounts a company has transferred to the special account supporting the Armed Forces.
- The loan limit, effective 14 January 2026, matches funds received in Ukraine after 1 January 2026 under qualifying loan agreements.
None of these three helps a founder who simply wants to capitalise a new entity abroad. They exist to unlock stuck obligations, not to open a channel for outbound capital.
A detail worth knowing
Transactions valued below UAH 400,000 fall outside foreign exchange supervision entirely. Settlement periods for export and import operations run to 180 calendar days. A longer 270-day period was introduced from 15 June 2026, but it is narrow: it applies to exports only, and only to pipes and to parts for railway rolling stock. These thresholds matter more than founders expect, because they shape how service invoicing between related entities gets structured.
Why the Share Capital Wire Will Be Refused
Here is where theory meets a compliance officer.
Resident individuals and companies cannot transfer funds abroad to acquire shares in, or contribute capital to, a foreign entity while the current framework applies. The pre-war electronic limit that once allowed individuals to send up to EUR 100,000 a year for investment purposes has not been restored. The regulator has been explicit about this, having specifically restricted card-based quasi-cash operations because they were being used to work around the prohibition.
What people try, and what happens
- Card payments and peer-to-peer transfers: Capped at UAH 100,000 monthly for quasi-cash and for cross-border P2P. Using this route to fund a share subscription is not a workaround; it is the exact behaviour the cap was designed to catch. Ordinary card spending on goods and services abroad remains free of restriction, which is a different thing entirely.
- Sending it as a “loan” to a friend abroad: The receiving institution will ask about the economic purpose. Documentation that does not match the transaction creates
- Crypto conversion: Purchases of virtual assets sit inside the quasi-cash category, and therefore inside the same monthly ceiling.
- Cash across the border: Declaration thresholds apply, and arriving at a Cypriot institution with undeclared cash is the fastest way to have an application declined permanently.
Put bluntly: attempting to force capital out through an unpermitted channel typically costs more than the incorporation itself, and it poisons the banking relationship you are trying to build.
An individual permission exists
The regulator can grant a specific permit for an operation that falls outside the permitted categories. The applicant has to show the transaction matters to state interests during martial law. Realistically, a founder capitalising a private holding company will not clear that bar, though larger projects with strategic significance sometimes do.
Funding Routes That Genuinely Work
Now the useful part. Every structure we set up gets capitalised through one of the following, and usually a combination.
1. Capital already held outside the country
Money in an overseas account, prior earnings from work abroad, proceeds from assets sold outside the country, or savings held by a family member who is not resident. Nothing in the domestic framework touches funds that are already offshore, because the restrictions apply to transfers leaving the country, not to operations settled abroad.
This is the cleanest option by a wide margin. Documentation still matters, and the receiving institution will want to see where the money originated.
2. Direct client revenue
The strongest route for operating businesses, and the one most founders overlook. Your new entity signs contracts in its own name, invoices clients directly, and receives payment into its own account. Capital requirements become almost irrelevant, since the company funds itself from trading receipts within weeks.
Practical steps:
- Sign new client agreements with the incorporated entity rather than novating everything at once
- Give clients updated invoicing details and banking instructions
- Keep the commercial substance genuine, meaning the entity really does contract, deliver and bear risk
- Document the transition properly, because tax authorities on both sides will eventually look at it
3. A shareholder loan from outside
Where a co-founder, family member or partner is resident elsewhere, they can lend to the company directly. Loan agreements should be written, dated and priced sensibly. Repayment terms need to be realistic rather than nominal, and interest, if charged, should sit at a defensible rate.
4. Third-party investment
Angel money, venture capital or a strategic partner all arrive from outside the restricted perimeter. This route also solves the share capital question, though it obviously brings dilution and governance consequences that have nothing to do with exchange rules.
5. Genuine trade payments from a Ukrainian entity
An existing company in Ukraine can pay for imported works and services, and this category is fully open. Where the new entity provides something real, development work, licensing, management support, invoices can be settled without restriction.
Two warnings, though. This is a trade payment, not a capital contribution, so it does not increase share capital. And transfer pricing rules apply to related-party arrangements, meaning the pricing must be defensible and the services must actually be provided. Invented invoices used as a capital channel are the single most common reason a structure later collapses under audit.
6. Relocation
Founders who cease to be resident stop being subject to the framework in respect of their own funds held abroad. Residence change is a substantial decision with consequences well beyond exchange rules, but for some it resolves several problems at once.
How much capital do you actually need?
Less than most people assume. A private limited company in the Republic has no statutory minimum paid-up share capital. Typical nominal capital is set at EUR 1,000, divided into 1,000 shares of EUR 1 each, and it does not all have to be paid up on day one. Operating costs, not statutory capital, drive the real funding requirement.
The Receiving Side: No Restrictions, But Plenty of Questions
Worth remembering that the destination went through its own version of this. Capital controls were imposed there in March 2013 during the banking crisis, and lifted entirely in April 2015. Nothing restricts inbound or outbound transfers today.
What you meet instead is anti-money-laundering scrutiny, and for applicants connected to Ukraine it is thorough.
What onboarding will ask for
- Passport and proof of residential address
- Structure chart showing beneficial ownership through to individuals
- Source of wealth: how you accumulated your money over your career
- Source of funds: where this particular money came from
- Business plan, expected turnover, main counterparties and countries involved
- Sample contracts or invoices supporting the projected activity
Source of wealth and source of funds are treated as separate questions, and answering only one of them causes most delays we see.
Traditional institutions or an EMI?
Both work, and the right answer depends on what the company actually does.
| Consideration | Traditional bank | Electronic Money Institution |
| Onboarding time | Longer, often several weeks | Usually faster |
| Documentation depth | Heavier, particularly for higher-risk profiles | Lighter but still substantial |
| Deposit protection | Covered by the deposit guarantee scheme | Funds safeguarded, not covered by deposit guarantee |
| SEPA and SWIFT | Both | SEPA standard, SWIFT varies by provider |
| Cards and multi-currency | Available | Often stronger, with more currencies |
| Credit facilities | Available | Rarely |
Many of our clients open both. An EMI account gets operations moving quickly, while the bank application proceeds on its own timetable. Holding balances in one place and running payments through another is entirely normal, and it removes the risk of being stuck if a single provider changes its risk appetite.
Taking Profits Out, and Bringing Them Home
Getting money in is only half the exercise. Founders should model the exit before incorporating, not afterwards.
From the company to you
Three usual mechanisms, each treated differently:
- Dividends: As a general rule no withholding is applied on dividends paid to shareholders who are not tax resident in the Republic. From 1 January 2026 there are two exceptions: 5% applies where the recipient is an associated company resident or incorporated in a low-tax jurisdiction, meaning one whose corporate rate is below half the Cyprus rate, and 17% where the recipient is in a jurisdiction on the EU list of non-cooperative jurisdictions. Association means a direct or indirect holding of at least 50%, and neither charge applies to payments made to individuals. Where the shareholder is tax resident there and domiciled, a 5% defence contribution applies to distributions from profits earned in 2026 onwards, with a transitional 17% rate on distributions out of profits earned up to 31 December 2025 that are received on or before 31 December 2031. The health system contribution of 2.65% applies to dividends for Cyprus tax residents including non-domiciled ones, subject to an overall annual income ceiling of EUR 180,000.
- Director’s remuneration or salary: Deductible for the company, subject to personal taxation and social contributions where the role is genuine.
- Loan repayment: Returning capital previously lent by a shareholder, which carries no charge on the principal.
Corporate profits are taxed at 15% from 1 January 2026 before any of this happens.
Back into Ukraine
Inbound transfers are not restricted. Money arriving from abroad into a resident account passes without the obstacles that apply in the opposite direction, which strikes most people as counterintuitive until they think about why the framework exists.
Tax follows, of course. Dividends from a foreign entity received by a resident individual attract personal income tax at 9% plus the 5% military levy, giving 14% in total. The military levy is payable in Ukraine in full and cannot be reduced by credit for foreign tax; only the personal income tax element is creditable, and only with the documentation the treaty requires.
The obligation nobody mentions in the pitch
Holding a foreign company while remaining tax resident in Ukraine puts you inside the controlled foreign company regime. Notification within 60 days of acquiring the interest, annual reporting, and potentially taxation of adjusted profit all follow. That obligation attaches to your personal residence, not to the entity, and it applies whether or not any money ever moves.
Highworth builds these structures properly from the start. Company formation is our primary service, and we handle incorporation, registered office, corporate secretarial work, banking introductions through both traditional institutions and Electronic Money Institutions, management accounts, fiduciary services, legal support and immigration assistance. Statutory audit is carried out by an independent audit firm, which we coordinate for you.
This article is general information as at August 2026 and is not advice on any particular transaction. The Ukrainian currency position changes frequently and should be confirmed with a Ukrainian adviser or your servicing bank before funds move.
Frequently Asked Questions
Can my Ukrainian company become a shareholder in the Cypriot entity instead of me personally?
The same prohibition applies. A resident legal entity cannot transfer funds abroad to acquire corporate rights in a foreign company under the current framework, so the shareholding would have to be created without an outbound payment. Structures of this kind are usually built by having the foreign entity issue shares against a receivable, contributed assets, or subscription funds already held offshore. Each variant carries valuation and reporting consequences in both jurisdictions and should be documented before, not after, execution.
How long does it take to open an account for a newly formed company?
An Electronic Money Institution account can often be operational within one to two weeks once the corporate documents and beneficial owner file are complete. Traditional institutions generally take four to eight weeks, sometimes longer where the ownership chain is complex or the activity is considered higher risk. Preparing the source of wealth narrative, structure chart and supporting contracts in advance is the single most effective way to shorten either timeline.
Will my company be refused simply because the owner is connected to Ukraine?
No, though enhanced due diligence is standard and takes longer. Applications are assessed on the individual profile: how wealth was accumulated, whether the activity makes commercial sense, which counterparties and countries are involved, and whether sanctions exposure exists anywhere in the chain. Well-documented applications from technology, consulting, trading and professional services businesses are approved routinely. Thin documentation, vague activity descriptions and unexplained third-party payments cause the refusals.
What happens if martial law ends?
Restrictions imposed under the martial law framework would be reviewed rather than automatically cancelled, and the regulator has published a gradual liberalisation path rather than a single switch. Full easing is expected to follow macroeconomic stabilisation, exchange rate conditions and reserve levels. Structures should therefore be built on the rules currently in force, not on an assumed reopening, while remaining flexible enough to take advantage of easing when it arrives.
Are there penalties for breaching the restrictions?
Yes. Fines apply for violations of currency legislation, banks are required to refuse non-compliant operations, and repeated issues can lead to accounts being closed on both sides of the transfer. More damaging in practice is the reputational consequence: a declined or unwound transaction becomes part of your compliance history and follows you into every subsequent application. Structuring correctly at the outset costs considerably less than remediation.
Set Your Structure Up the Right Way From Day One
Funding and profit extraction are not afterthoughts. They determine whether your new company works in practice or sits idle waiting for money that cannot legally reach it.
Speak to Highworth before you incorporate. We will map the funding route that fits your circumstances, form the company, and open the accounts that let it start trading.
