Legal entities - owners of international business must report on controlled foreign companies by March 3

Ukrainian legal entities that have controlled foreign companies (CFCs) are required to submit the relevant Report to the tax authority by March 3, 2025. Individuals with CFCs have until May 1, 2025 to report.

Who has to submit the CFC Report?

The controlling persons of a CFC may be legal entities and individuals resident in Ukraine who

- own more than 50% of the share in the CFC;

- own at least 10% of the share in the CFC, if in total residents of Ukraine own more than 50%;

- Exercise actual control over the CFC (dispose of assets, income, make management decisions).

Legal entities submit the Report together with the corporate income tax return.

Duly certified copies of the CFC's financial statements confirming the amount of the CFC's profit for the reporting year are attached to the Report.

The CFC Report shall contain the following information:

- Name, address, OPF, registration numbers of the CFC, share of the controlling person, ownership structure (if the share is indirect).

- Income according to financial statements, adjusted profit, grounds for tax exemption.

- Dividends, paid out profits, transactions with non-residents (related parties and jurisdictions included in the CMU Resolution).

- Number of employees, income from a permanent establishment in Ukraine.

For reference.

The legal regulation of the activities of Ukrainian residents who control CFCs is carried out in accordance with Article ³⁹² of the TCU.

Failure to submit, untimely submission of the Report, or submission of inaccurate information may result in significant financial consequences (Article 120.7 of the TCU).

The Ministry of Finance of Ukraine by its Order No. 254 dated August 25, 2022 approved:

- the form of the CFC Report;

- the form of the abbreviated CFC Report;

- procedures for filling in the CFC Report, the shortened form of the Report and submission to the supervisory authority.