The list of incomes received by a non-resident with a source of their origin from Ukraine is established by paragraphs. 141.4.1 Art. 141 TCU.

In view of the fact that membership fees are not specified in paragraphs 141.4.1 Art. 141 TCU as a separate source of income received by a non-resident with a source of origin from Ukraine, such payments are considered as part of other income from the conducting of economic activity in the territory of Ukraine by a non-resident or a permanent representation of that or another non-resident.

Therefore, if a resident pays any income from source income from Ukraine received by a non-resident (including non-resident accounts held in the national currency), the tax on such proceeds as specified in pp. 141.4.1 Art. 141 TCU, at a rate of 15%. The exception is the income specified in subparagraphs 141.4.3 - 141.4.6 of Art. 141 TCU, as well as the situation, unless otherwise stipulated by the provisions of international treaties of Ukraine with the countries of residence of persons whom payments are made for (clause 141.4.2 item 141 TCU).

So, if the payment of income with a source of its origin from Ukraine is in favor of an international organization that has immunity under international treaties, then such income is not taxable in Ukraine.

Thus, it can be concluded that in the case of a resident payment of membership fees in favor of a non-resident, a tax of 15% of its sum and at the expense of such a non-resident in the payment of such contributions is retained, unless otherwise provided by the provisions of the applicable international treaties.