- May 10, 2026
- Posted by: АРОУ
- Category: Publications
Since 2022, Ukraine has implemented comprehensive rules regarding Controlled Foreign Companies (CFCs). One of the key obligations for Ukrainian tax residents is the timely submission of CFC reporting. Failure to comply may result in significant penalties and additional legal risks.
This article outlines the main reporting deadlines, applicable penalties, and practical recommendations for business owners.
Who Must Submit CFC Reporting?
Reporting obligations apply to Ukrainian residents who control foreign companies qualifying as CFCs.
Control exists if a resident:
- owns more than 50% of the foreign company;
- owns more than 10% if several Ukrainian residents jointly own more than 50%;
- or exercises actual control over the company.
What Reports Must Be Submitted?
Notification of a CFC
Information about the CFC must be disclosed in the annual tax declaration.
CFC Report
The report includes:
- corporate structure information;
- financial statements;
- profit or loss data;
- tax calculations.
Reporting Deadlines
- The CFC report must be submitted together with the annual tax declaration for the relevant tax year.
- In most cases, the deadline is May 1 of the following year.
For example:
- the report for 2024 must be submitted by May 1, 2025.
What Penalties Apply?
| Violation | Penalty |
|---|---|
| Failure to notify about a CFC | UAH 100,000 per CFC |
| Failure or late submission of a CFC report | UAH 300,000 per CFC |
| Failure to provide supporting documentation | UAH 300,000 per CFC |
| Repeated violation within 3 years | Double penalties |
Practical Recommendations
Plan Ahead
Identify existing CFCs and prepare reporting documents well before the deadline.
Work with Professionals
Legal and tax advisors can help structure reporting correctly and reduce risks.
Document Control Properly
Clearly establish and document the existence or absence of control over foreign entities.
Monitor Financial Reporting
Even dormant or loss-making companies must be disclosed if they qualify as CFCs.
Do Not Ignore Deadlines
Late submission may trigger substantial financial penalties.
If You Missed the Deadline — Act Quickly
Submit amended reports and seek legal assistance to minimize consequences.
Why Legal Support Matters
CFC compliance is not only a tax issue but also a matter of international business structuring, financial security, and regulatory transparency.
The Ukrainian Bar and Real Estate Association provides comprehensive support for owners of foreign companies, including:
- corporate structure analysis;
- CFC compliance support;
- preparation and submission of reports;
- assistance during tax audits;
- representation in tax disputes.
