Campaign for submitting reports on controlled foreign companies for 2024 is ongoing: deadline is May 1, 2025

Press service of the State Tax Service of Ukraine, published 15 April 2025 at 15:02 Chapter: News

Campaign for submitting reports on controlled foreign companies by individuals – controllers for the reporting period 2024 is ongoing.

If you are resident of Ukraine and have a stake or control over the foreign company, you are required to submit Report on controlled foreign companies together with annual income tax declaration by May 1, 2025.

Report is submitted electronically together with property and income declaration (Sub-paragraph 39².5.2 Paragraph 39².5 Article 39² and Sub-paragraph 49.18.7 Paragraph 49.18 Article 49 of the Tax Code of Ukraine (hereinafter – Code))).

Duly certified copies of financial reporting of the controlled foreign company for relevant period have to be attached to the Report.

Controlled foreign companies are subject to tax control according to Article39² of the Code.

State Tax Service continues to receive information regarding the ownership of controlled foreign companies by controlling entities from foreign competent authorities, databases, media, etc.

It should be reminded of the need to report on each controlled foreign company.

Fines are provided for failure to submit or untimely submission of Report according to Paragraph 120.7 Article 120 of the Code.

Important! From 01.01.2024, criteria for owning stake in the controlled foreign companies in the amount of more than 10% will apply, provided that several residents of Ukraine collectively own 50 percent or more.

Other criteria are defined in Paragraph 39².1 Article 39² of the Code.

At the same time, controlling entities should pay attention to filling out line 29 of the Report on controlled foreign companies, which should indicate amounts of dividends received by foreign companies from Ukrainian legal entities.  

This income must be included in the annual income declaration of an individual, as it is considered income of the controlling entity. Such income is subject to the personal income tax and military levy (Sub-paragraph 170.13.3 Paragraph 170.13 Article 170 of the Code).

Follow requirements of Article 39² of the Code to avoid possible violations.

For reference.

Form of the Report on controlled foreign companies, Procedure for its completion and submission to the controlling authority was approved by Order of the Ministry of Finance of Ukraine “On approval of form of the Report on controlled foreign companies, the abbreviated form of Report on controlled foreign companies, Procedure for filling out the Report on controlled foreign companies, the abbreviated form of the Report on controlled foreign companies and submission to the controlling authority and Changes to form of the corporate income tax declaration № 254 as of 25.08.2022”.