Reporting on Controlled Foreign Companies (CFC)

In accordance with the Tax Code of Ukraine, every owner of a controlled foreign company (CFC) is required to submit an annual CFC report. Before filing the report, it is important to determine which documents need to be prepared and whether the report's structure meets the requirements of Ukrainian legislation.

Requirements for filing CFC reports

• CFC reports are filed annually by the controlling person.

• The CFC report is filed together with the relevant annual tax return.

• Properly certified copies of the CFC's financial statements are attached to the report in the cases and in the manner prescribed by the Tax Code of Ukraine.

• The CFC report is filed separately for each controlled foreign company.

• CFC reports are filed electronically.

Deadlines for filing the CFC report

Please note! The absence of business activity or profit at the CFC does not by itself release the controlling person from the obligation to file a report. The obligation to file a report is determined based on the status of the controlling person and other conditions prescribed by the Tax Code of Ukraine. In particular, an obligation to file a report may arise even in the absence of taxable CFC profit.

Types of CFC reports

Depending on whether financial statements can be prepared, one of two types of reports is filed:

• Full report: contains all the required information and confirmed financial statements.

• Short-form report: filed if it is not possible to prepare the CFC's full financial statements by the deadline.

The CFC report is filed separately for each controlled foreign company and exclusively in electronic form.

If a short-form report was filed for the 2025 reporting year due to the inability to timely prepare the CFC's financial statements, the full report must be filed by December 31, 2026.

CFC reporting period

• The reporting (tax) period is a calendar year or another CFC reporting period that ends during a calendar year. In many foreign countries, a company's financial year corresponds to the calendar year, beginning on January 1 and ending on December 31.

• If a company's financial year does not coincide with the reporting/calendar year, as in the United Kingdom for example, the CFC's financial statements must be filed for the period ending during the calendar year required for filing the CFC report.

What needs to be attached to the CFC report?

The following must be attached to the CFC report:

• Properly certified copies of the CFC's financial statements confirming the amount of the CFC's profit for the reporting (tax) year.

• If the company's country of registration does not require the filing of financial statements, our accountants can help prepare such financial statements in accordance with international standards and the requirements established by the Tax Code of Ukraine.

• If a person does not have time to prepare the financial statements by the deadline for filing the annual return, in the cases provided for by law they may first file a short-form report and later file the full report.

If the deadline for preparing financial statements in the relevant foreign jurisdiction expires later than the deadline for filing the Ukrainian annual return, the law allows, in established cases, for the relevant copies of the financial statements to be filed together with the return for the next reporting period.

How Maira Consult helps with CFC reporting

Maira Consult's specialists have successful experience filing CFC reports and offer a full range of services:

• Consultations on CFCs;

• Analysis of the foreign company's structure;

• Determining owners' obligations regarding CFC reporting;

• Determining reporting periods;

• Preparing CFC reports;

• Preparing the annual declaration of property status and income;

• Compiling financial statements in accordance with international standards;

• Support in filing reports with the tax service.

If during the year there was an acquisition of a share, a change in the size of participation, or termination of control over the CFC, the obligation to file a CFC notification within 60 calendar days must also be checked.

As a result, you will receive professional support in preparing and filing CFC reports in accordance with the requirements of Ukrainian legislation.

Don't risk penalties! Entrust the preparation of your CFC reporting to the professionals at Maira Consult.