Deadline for submission of the full Report on Controlled Foreign Companies expires

The State Tax Service of Ukraine draws the attention of CFC controllers to the fact that on December 31, 2024, the deadline for submitting the full Report on Controlled Foreign Companies (hereinafter referred to as CFCs) for the 2023 reporting (tax) year expires in accordance with subparagraph ³⁹².5.4 of the Tax Code.

Thus, as of December 01, 2024, controlling persons submitted 10395 reports on CFCs in a shortened form, of which only 19% submitted full CFC Reports.

Each controller is required to submit a CFC report annually. If they have several CFCs, the report is submitted for each CFC separately.

The Report must be accompanied by duly certified copies of the CFC's financial statements confirming the amount of the CFC's profit for the reporting (tax) year.

The form of the CFC Report was approved by the Order of the Ministry of Finance dated 25.08.2022 No. 254.

Electronic forms of documents are available on the State Tax Service's web portal in the section "Electronic Reporting/To Taxpayers on Electronic Reporting/Information and Analytical Support/Register of Electronic Forms of Tax Documents" (forms J0108701 and F0108701).

At the same time, paragraph 120.7 of Article 120 of the Code, in particular, provides for the imposition of the following fines

- Failure of the controlling person to submit the CFC Report shall result in a fine in the amount of 100 times the minimum subsistence level for an able-bodied person established by law as of January 1 of the tax (reporting) year;

- untimely submission of the CFC Report by the controlling person entails 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.