State Tax Service received the first CbC reports from 21 foreign jurisdictions

Press service of the State Tax Service of Ukraine, published 26 June 2025 at 14:16 Chapter: News

State Tax Service of Ukraine received the first Country-by-Country (CbC) reports within framework of the automatic exchange of information from 21 foreign jurisdictions. This was made possible by the entry into force of the Multilateral Competent Authority Agreement – CbC MCAA on July 4, 2024.

Identified deficiencies are transferred to partner states according to provisions of the Multilateral Agreement.

State Tax Service of Ukraine exercises tax control over the transfer pricing by monitoring submission of the country-by-country reports of the international groups of companies (CbC reports).

Based on notifications on participation in the international groups of companies, the State Tax Service identifies taxpayers who are required to submit CbC reports. Taxpayers carrying out controlled transactions must submit relevant notification on participation in the international groups of companies by October 1 each year.

CbC report must be submitted not later than 12 months after the end of financial year established by the parent company. In the absence of information on financial year established by the parent company for the international groups of companies – within 12 months after the end of calendar year.

State Tax Service analyzes submitted reports for completeness, accuracy and compliance with requirements of the Tax Code of Ukraine. In case of errors or discrepancies, payers will receive notification with a requirement to submit clarifying report or provide explanation within 30 days.

In the absence of valid QCAA with the jurisdiction of tax residence of the parent company, the CbC report for 2024 must be submitted by the Ukrainian resident independently. Relevant QCAA agreement has not entered into force as of December 31, 2024, in particular with the USA, Canada and Israel.

Please note: failure to submit, late submission or provision of inaccurate information in the CbC reports or notifications on participation in the international groups of companies entails penalties according to Article 120 of the Tax Code.