Ukraine has joined the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports

State Tax Service of Ukraine, as a competent authority of Ukraine, joined the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (hereinafter – Multilateral Agreement CbC) on November 3, 2022.

Joining the Multilateral Agreement CbC is carried out for the purpose of implementing Sub-paragraphs 39.4.10 – 39.4.15 of Paragraph 39.4 Article 39 Section I of the Tax Code of Ukraine regarding the automatic exchange of country-by-country reports of the international groups of companies, as well as implementation of the BEPS (Base Erosion and Profit Shifting) Action Plan, in particular, Step 13 – introduction of additional reporting on the transfer pricing for international groups of companies.

Direct implementation of such exchange is one of Ukraine's international obligations and involves establishment of the State Tax Service’s obligation to collect relevant information and annually on an automatic basis to exchange reports on the country-by-country basis between jurisdictions in which  member of the international group of companies is registered or in which the international group of companies is registered carries out its activities, containing information, in particular, regarding the total amount of income (revenue) per a financial year, amount of profit (loss) per a financial year, amount of accrued and paid corporate income tax, size of the authorized capital, number of employees per a financial year, etc.