Is it necessary to submit the CbC Report for the first time for a fiscal year in which the Multilateral CbC Agreement entered into force for the taxpayers who meet circumstances of Clauses 4 – 7 of Sub-paragraph 39.4.10 Paragraph 39.4 Article 39 of the Code, in which a fiscal year established by the parent company of the international group of companies does not coincide with a calendar year?
Answer
Yes, it is necessary.
The CbC report is prepared for a fiscal year established by parent company of the international group of companies, even if it does not coincide with a calendar year.
Report must be submitted not later than 12 months after the last day of such fiscal year.
If there is no information about the fiscal year established by parent company of the international group of companies, then submission deadline is within 12 months after the end of a calendar year.
Requirement to submit the CbC Report by the taxpayers who meet circumstances of Clauses 4 – 7 of Sub-paragraph 39.4.10 Paragraph 39.4 Article 39 of the Code first applies to the fiscal year beginning in a period from January 1 to December 31 of year in which the Multilateral CbC Agreement entered into force with at least one foreign jurisdiction – partner of Ukraine for the automatic information exchange.
By what deadline must the taxpayers who meet circumstances of Clauses 4 – 7 of Sub-paragraph 39.4.10 Paragraph 39.4 Article 39 of the Code, in which the fiscal year established by parent company of the international group of companies begins in a period from July 1, 2024 to June 30, 2025, submit the CbC Report?
Answer
If the company’s fiscal year, established by parent company of the international group of companies, begins on July 1, 2024 and ends on June 30, 2025, then deadline for submitting the CbC Report for the specified fiscal year is not later than June 30, 2026.