Ukraine continues to integrate into the global tax transparency system: to date, the CbC reports have been received from 29 of the 45 countries from which information for the fiscal year 2024 is expected. In total, data from 35 foreign partners on more than 700 international groups of companies has been received within the framework of international exchange.
CbC (Country-by-Country Reporting) reports are important tool for automatic exchange of tax information, which allows obtaining summarized data on the distribution of income, profits and taxes of international groups in different jurisdictions.
Ukraine’s accession to the Multilateral Agreement on the Automatic Exchange of the CbC Reporting, which entered into force in 2024, opened up access to such data set. Currently, Ukraine can potentially exchange reports with 111 partner countries that have agreed to such interaction.
At the same time, reports from 45 countries are expected to be received in 2026. Exchange process is ongoing and after checking completeness and reliability of received data, Ukraine has already sent relevant reports to other participants.
Information obtained is used exclusively for assessing tax risks. Particularly, it allows to:
- analyze distribution of profits between jurisdictions;
- identify potential cases of tax base erosion;
- identify transfer pricing risks;
- develop risk-based approach to tax control.
If discrepancies are found in the CbC reports, notification is sent to the payer. Revised report and explanation must be submitted within 30 calendar days. Failure to comply with this requirement is considered late submission and will result in penalties for each day of delay.
Introduction of such mechanisms is part of Ukraine’s systematic work on implementing international standards, particularly BEPS initiative. This increases efficiency of tax control and strengthens trust of international partners in the Ukrainian tax system.