In 2024, controlled foreign companies submitted both full and abbreviated reports, and we strongly recommend doing the same in 2025. Why? Our clients who registered a company at the beginning of 2024 have already received notifications from the State Tax Service about the mandatory submission in 2025 and outlining the penalties for non-compliance.
Rules in Ukraine Are Governed by the Following Laws:
- “On Amendments to the Tax Code of Ukraine to Improve Tax Administration, Eliminate Technical and Logical Inconsistencies in Tax Legislation”
- “On Amendments to the Tax Code of Ukraine and Other Laws of Ukraine to Ensure the Collection of Data and Information Necessary for Declaring Certain Taxable Objects”
When Is a CFC Consultation Needed for Ukrainians?
A consultation on controlled foreign companies (CFC) is essential for entrepreneurs engaged in international business who want to mitigate risks related to CFC reporting and taxation.
Formats:
- Oral consultation – for quick answers to questions about CFC reporting and taxation.
- Comprehensive written consultation – for detailed analysis of the client’s case, outlining all applicable international conventions and providing recommendations on report submission.
When Should You Request a CFC Consultation?
- Before submitting a CFC report – if your company has a complex corporate structure with multiple owners or if it is unclear who is required to submit the report. In some cases, all company participants must report; while in others, only the primary owner, depending on ownership shares and influence. A consultation will help you understand reporting rules, avoid double declarations, and minimize the risk of tax penalties.
- Before registering a foreign company – if you are planning to set up a business abroad but want to assess tax risks and obligations related to CFC status in advance. Choosing the wrong jurisdiction or structuring the company incorrectly can lead to high tax burdens, mandatory annual reporting, and potential conflicts with tax authorities. A consultation allows you to design your business structure to minimize tax risks and comply with legal requirements.
- If you already own a foreign company but are unsure whether it falls under controlled foreign companies rules, whether reporting is required, what tax obligations arise, or how its activities may impact your tax residency in Ukraine.
A consultation will help optimize your business structure, prepare reports correctly, avoid tax risks, and conduct international business with confidence.
