A full CFC report must be submitted by December 31, 2024

The tax authorities inform that the deadline for submission of the full report on controlled foreign companies (CFCs) for the 2023 reporting (tax) year in accordance with subparagraph 392.5.4 of the Tax Code expires on December 31, 2024.

Please note that each controller is obliged to submit an annual report on CFCs by electronic means in electronic form in compliance with the requirements of the Laws of Ukraine "On Electronic Documents and Electronic Document Management" and "On Electronic Identification and Electronic Trust Services".

The CFC report must be accompanied by duly certified copies of the financial statements of the controlled foreign company confirming the amount of profit of the controlled foreign company for the reporting (tax) year.

The form of the CFC Report was approved by the Order of the Ministry of Finance No. 254 dated August 25, 2022.

At the same time, paragraph 102.7 of the Tax Code provides for the following penalties

- Failure of the controlling person to submit a report on controlled foreign companies entails a fine of 100 times the minimum subsistence level for an able-bodied person established by law as of January 1 of the tax (reporting) year.

- late submission by a controlling person of a report on controlled foreign companies shall entail a fine in the amount of one subsistence minimum for an able-bodied person established by law as of January 1 of the tax (reporting) year for each calendar day of non-submission, but not more than 50 subsistence minimums for an able-bodied person established by law as of January 1 of the tax (reporting) year.