Corporate, Commercial Law and Dispute Resolution · Contracts, Commercial Law and Transactions
CFC report in Ukraine is a substantive tax filing for a Ukrainian resident who qualifies as the controlling person of a foreign company. Complete reporting requires more than identifying the foreign entity: ownership, financial results, tax paid abroad and supporting documentation should be consistent across the report and the annual tax return.
Who files the report
The report is submitted by a controlling person who directly or indirectly owns or controls a foreign company under the criteria set by the Tax Code of Ukraine.
Company information
Core information normally includes the company name, country of registration, identification or tax number, company registration number, registered office and legal form.
Financial information
The report should reflect the CFC's income and expenses, net profit or loss, taxes accrued and paid, value of assets and information on dividends distributed by the company.
Ownership structure
Ownership disclosure covers the controlling person's interest, information on other beneficial owners and any joint-control arrangements relevant to the CFC status.
Audit information
If the foreign company has been audited, the filing may identify the audit, the audit firm and relevant information on the audit result.
Supporting documents
Documents commonly associated with the report include CFC financial statements, an auditor's report where available, evidence of the ownership structure, documents supporting any tax exemption and evidence of foreign taxation.
Filing period
The CFC report is filed together with the annual tax return of the relevant individual or legal entity. The filing deadline is generally by 30 April of the year following the reporting year.
Consequences of incomplete information
Incomplete or inaccurate reporting may lead to penalties, additional tax assessments, interest, additional audits and, where intentional conduct is alleged, potential criminal-law risks.
Preparation approach
Financial information should be collected in advance, the control structure should be reviewed before filing and supporting documents should be retained in a form that can be produced if the State Tax Service of Ukraine (STS) requests clarification.
CFC reporting package should present one coherent picture of the foreign company, its ownership, financial position and tax treatment. Consistency between the report, financial statements and ownership documents is central to a defensible filing position.
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Price: Controlled Foreign Company (CFC) Report: Mandatory Information and Supporting Documents