Customer request
We received a request from the client who was interested in analyzing the corporate structure of the foreign companies he owned in terms of obligations and risks associated with the implementation of the rules on controlled foreign companies (CFCs) in Ukraine.
Proposed solutions
Our specialists analyzed the corporate structure of the client's foreign companies and took into account a number of factors, including: the role of each company in the structure, the relevance of the company's jurisdiction in terms of working with foreign banks (requirements, blocking accounts, etc.), the costs of supporting and maintaining the companies, as well as the potential costs for preparing financial statements and CFC reports, the feasibility of using the company in the corporate structure in view of current trends.
We considered options for restructuring the corporate structure in the direction of simplification to minimize the client's expenses for support and maintenance of foreign companies, and to exclude unnecessary companies and companies from risky jurisdictions from the structure.
Result obtained by the client
The client's corporate structure was restructured in the direction of simplification and transparency to minimize the costs of maintenance and supporting foreign companies, reporting on companies, fulfilling obligations regarding controlled foreign companies in Ukraine and reducing the potential tax burden in Ukraine for the beneficiary.
In the process of restructuring, the client was also provided with full legal support for the submission to the tax authorities of Ukraine of CFC reporting for the reporting periods of 2022 and 2023, the submission of notifications about the loss of control of CFC, as well as preparatory work for the formation of reports on companies that were excluded from the corporate structure in order for the beneficiary to fulfill the obligations related to the CIC, which will arise for the 2024 reporting year.
