State Tax Service received more than 90 CbC reports for 2024

More than 90 members of international groups of companies operating in Ukraine submitted the country-by-country (CbC) reports in 2024. This is one of the key tools of international tax transparency, which allows the state to see real distribution of income, taxes and economic presence of business between the countries.

CbC reporting is object of automatic exchange of tax information between jurisdictions. Due to this, Ukraine gains access to comprehensive data regarding activities of large international groups and can effectively counteract practices of transferring profits offshore.

Deadline for submitting the CbC Reports for the financial year ending 31.12.2024 was December 31, 2025. In particular, 8 residents who are parent companies of the international groups submitted reports. They operate in various industries – from energy and agribusiness to transport and financial services.

At the same time, 2025 became the first full year of the Multilateral CbC Agreement, which entered into force in 2024. This means that reports for the financial year starting from January 1 to December 31, 2024 must also be submitted by Ukrainian participants of the international groups, if:

- they have been authorized by the parent company, or

- there is agreement on the exchange of tax information between Ukraine and country of the parent company, but the QCAA agreement has not yet come into effect.

Using this model in 2025, more than 80 Ukrainian companies submitted the CbC Reports as a part of groups with parent companies from the USA, Canada and Israel.

This approach creates level playing field for business: large international companies can no longer minimize tax liabilities by artificially redistributing profits. Taxes are paid where economic value is created, and therefore go to the Ukrainian budget, rather than “settling” in the low-tax jurisdictions.

State Tax Service of Ukraine monitors submission, completeness and accuracy of the CbC Reports. If there are risks of non-submission or untimely submission, the Tax Service sends written request to clarify information.

If errors are detected – both by the State Tax Service itself and by tax authorities of other countries – the payer receives notification and has 30 calendar days to:

- submit revised CbC Report, or

- provide an explanation.

Legislation provides for significant financial sanctions for violation of the CbC reporting requirements, in particular:

- failure to submit report – a fine of 1 000 subsistence minimums;

- untimely submission – 10 subsistence minimums for each calendar day of delay (but not more than 1 000 subsistence minimums);

- incomplete data in the report – 1% of income of relevant group member (but not more than 1 000 subsistence minimums);

- provision of false information about member of the international group of companies – 200 subsistence minimums.

Important: If the payer does not submit revised report within 30 days after being notified of the errors, this is considered late submission and a fine is charged for each calendar day of submission of the CbC Report.

At the same time, purpose of the CbC reporting is not only to apply sanctions, but primarily to ensure tax transparency of activities of the international groups of companies. Summarized data from the CbC Reports allow the State Tax Service to identify markers of the transfer pricing risks, tax base erosion and profit shifting between jurisdictions, which is the basis for making informed decisions within the tax control framework.