Corporate, Commercial Law and Dispute Resolution · Contracts, Commercial Law and Transactions
CFC (Controlled Foreign Company) reporting after strike-off should be completed even when the foreign company has already been removed from its register. Formal termination of the legal entity and completion of the Ukrainian controlling person's tax obligations are separate steps and should be documented separately.
What Strike-Off or Deregistration Means
Removal from a company register ends the legal existence of the foreign entity under the relevant corporate procedure. This does not by itself eliminate outstanding CFC reporting obligations of the Ukrainian controlling person.
Final CFC Report
The final reporting package should reflect the period up to liquidation or termination and record the end of control. Relevant information may include:
financial results for the final period of activity;
information confirming termination;
distribution of remaining assets;
the date and circumstances in which control over the CFC ended.
Filing After the Company Has Closed
Reporting deadlines continue to matter after the company has been removed from the register. Late or incomplete filing may lead to penalties, additional tax assessments or further questions from the tax authority.
Tax Consequences of Liquidation Distributions
Dividends, cash, property or other value received by the controlling person during liquidation may have Ukrainian tax consequences. The distribution should therefore be analysed separately from the company's strike-off itself.
Documents to Retain
liquidation or strike-off documents;
official registry extracts;
final or liquidation financial statements;
bank statements and payment records;
proof of CFC report submission;
tax calculations relating to distributions or final income.
Closing the Compliance File
A useful final review confirms that the entity is no longer registered, the controlling relationship has ended, final financial information has been reported and any resulting tax has been addressed. These records should be retained even though the foreign company no longer exists.
CFC closure strategy should coordinate company strike-off, final financial statements, liquidation distributions and the last Ukrainian filing as one controlled process. Proper closure prevents a terminated foreign company from leaving unresolved reporting obligations for its former owner.
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Price: Closing Controlled Foreign Company (CFC) Reporting After a Foreign Company Is Struck Off