Legal entities - owners of international business must report on the controlled foreign companies by March 3

Ukrainian legal entities that have controlled foreign companies are required to submit relevant Report to the tax authority by March 3, 2025 inclusively. Individuals that have controlled foreign companies report by May 1, 2025.

Who must submit Report on controlled foreign companies?

Controlling entities of the controlled foreign companies may be legal entities and individuals residents of Ukraine, who:

- own more than 50% of shares in the controlled foreign companies;

- have at least 10% of shares in the controlled foreign companies, if residents of Ukraine collectively own more than 50%;

- exercise actual control over the controlled foreign companies (manage assets, income, make management decisions).

 Legal entities submit Report together with the corporate income tax declaration.

Report has to be accompanied by duly certified copies of financial reporting of the controlled foreign companies, confirming amount of profit of the controlled foreign companies for the reporting year.

Report on the controlled foreign companies states:

- Name, address, organizational and legal form, registration numbers of the controlled foreign companies, share of the controlling entity, ownership structure (if share is indirect).

- Income according to financial reporting, adjusted profit, grounds for exemption from taxation.

- Dividends, paid profit, transactions with non-residents (related entities and from jurisdictions included in Resolution of the Cabinet of Ministers).

- Number of employees, profit from a permanent establishment in Ukraine.

For reference.

Legal regulation of activities of residents of Ukraine who control the controlled foreign companies is carried out according to Article 39 Note 2 of the Tax Code of Ukraine (hereinafter – Code).

Non-submission, untimely submission of the Report, or provision of the inaccurate information may lead to significant financial consequences (Article 120.7 of the Code).

Ministry of Finance of Ukraine by Order № 254 as of 25.08.2022, approved:

- form of Report on the controlled foreign companies;

- form of the abbreviated Report on the controlled foreign companies;

- procedures for filling out Report on the controlled foreign companies, abbreviated form of the Report and submission to the controlling authority.