5 Ukrainian parent companies submitted CbC Reports for 2023

5 Ukrainian payers, that are parent companies of the international groups of companies, submitted the Country-by-Country Report (CbC) for the 2023 fiscal year as of January 1, 2025.

They work in the following industries:

Oil and Gas

Electric Power

Agriculture

Rail Transportation

Vehicle Manufacturing

These international groups of companies include 143 companies, of which only 11 (8%) are not residents of Ukraine. Members of the international groups of companies are registered, in particular, in Austria, Belgium, Cyprus, Poland, Slovakia, Switzerland. 

The CbC Report is a component of the three-tier transfer pricing documentation.

Exchange of the CbC Reports is carried out automatically. Tax authorities receive comprehensive data regarding activities of the international groups of companies in different jurisdictions.

Deadline for submitting the CbC Report for 2023 is December 31, 2024.

State Tax Service of Ukraine checks timeliness and correctness of submission of the CbC Report. In case of untimely submission or errors in the Report, the State Tax Service sends a written notification to the payer. 

Payer is obliged, not later than 30 calendar days from the date of receipt of notification from the State Tax Service:

submit revised CbC Report with corrections

or

provide explanation.

Penalties for violations

1. Failure to submit the CbC Report:

1000 subsistence minimums for an able-bodied person as of January 1 of the reporting year (Paragraph 120.3 Article 120 of the Tax Code).

2. Untimely submission (including the CbC clarification report):

10 subsistence minimums for each day of  delay, but not more than 1000 subsistence minimums for a year (Paragraph 120.6 Article 120 of the Tax Code).

3. Absence of information in the Report about a participant of the international groups of companies according to requirements of Article 39 of the Tax Code (Paragraph 120.4 Article 120 of the Tax Code):

1% of income of such participant, but not more than 1000 subsistence minimums.

4. Inaccurate data (Paragraph 120.5 Article 120 of the Tax Code):

200 subsistence minimum fine.

If the revised CbC Report is not submitted within 30 calendar days from the date of receipt by the State Tax Service notification, the company receives a fine for each day of delay, starting from the 31st calendar day.

If the payer independently or not later than 30 calendar days from the date of receipt by the State Tax Service notification corrected errors that did not affect identification of: the state/territory of participants in the international groups of companies and/or jurisdiction of submission of the CbC Report and/or each of participants in the international groups of companies, the fine for inaccurate data is not applied.