2026

Ukrainian Controlled Foreign Company (CFC) legislation contains numerous rules regarding reporting obligations for Ukrainian tax residents. One of the most common questions is whether a taxpayer must separately notify the State Tax Service of Ukraine if a foreign company qualifies for an exemption from full CFC reporting. What Is CFC Reporting? CFC reporting is the

Ukrainian Controlled Foreign Company (CFC) legislation requires Ukrainian residents to declare and, in certain cases, pay taxes on profits earned by foreign companies under their control. However, not all CFCs are subject to taxation in Ukraine. A Controlled Foreign Company is a foreign legal entity controlled by a Ukrainian tax resident — either an individual

Since the introduction of Controlled Foreign Company (CFC) rules in Ukraine, businesses using foreign structures have faced new tax and legal obligations. However, not every foreign company is automatically recognized as a CFC, meaning full reporting obligations do not always apply. This article explains the key exceptions to CFC rules, available reporting exemptions, and common

Since the Controlled Foreign Company (CFC) rules came into force in Ukraine, Ukrainian residents owning foreign businesses have become obligated to submit annual CFC reports. However, Ukrainian legislation provides several situations where a foreign company may not qualify as a CFC or where the controlling person may benefit from exemptions and simplified reporting. What Is

The introduction of Controlled Foreign Company (CFC) rules in Ukraine became part of the global de-offshorization process. Owners of foreign businesses who qualify as controlling persons are required to submit reports to the State Tax Service of Ukraine. This article explains what information must be included in a CFC report in order to avoid tax

Since 2022, Ukrainian taxpayers have been required to submit reports regarding Controlled Foreign Companies (CFCs). Despite businesses gradually adapting to the new requirements, many controlling persons still make mistakes that may lead to penalties, tax audits, and even criminal risks. 1. Failure to Submit or Late Submission of Reports This is the most common violation

Since the introduction of Controlled Foreign Company (CFC) rules in Ukraine, owners and controlling persons of foreign structures have come under increased scrutiny from tax authorities. Many business owners ask whether violations of CFC legislation may lead to criminal prosecution and where the line lies between administrative and criminal liability. A Controlled Foreign Company is

Controlled Foreign Companies (CFCs) have become an increasingly common business structure for Ukrainian residents operating abroad. At the same time, taxation of CFC profits is one of the key issues affecting owners and controlling persons of such companies. A Controlled Foreign Company is a legal entity registered outside Ukraine and controlled by a Ukrainian tax

Controlled Foreign Companies (CFCs) are a common business structure used by Ukrainian residents operating internationally. However, one of the main challenges faced by CFC owners and controlling persons is the risk of double taxation of profits. This may lead to significant financial losses and disputes with tax authorities. In this article, we explain how to

Controlled Foreign Companies (CFCs) play an important role in the international business structures of Ukrainian entrepreneurs and companies. At the same time, Ukrainian legislation establishes clear taxation rules for profits generated by such companies in order to prevent tax avoidance. What Is a CFC and Who Is a Controlling Person? A Controlled Foreign Company is