CFC Reporting Submission: Required Documents and Filing Recommendations

Since 2022, Ukraine has implemented reporting requirements for Controlled Foreign Companies (CFCs). Ukrainian residents who own or control foreign companies must understand not only their reporting obligations but also what documents are required and where they must be submitted.

Who Must Submit CFC Reporting?

Reporting obligations apply to Ukrainian residents who control foreign companies classified as CFCs.

Control exists where a resident:

• owns more than 50% of the company;
• owns more than 10% if several Ukrainian residents jointly control more than 50%;
• or exercises actual management or control over the company.

List of Required Documents for CFC Reporting

Notification of CFC Ownership

The existence of a CFC must be disclosed in the annual tax declaration.

CFC Report

The report should include:

• general company information;
• registration details;
• country of incorporation;
• business activities;
• ownership structure;
• financial results;
• profit or loss calculations;
• tax calculations;
• additional operational information.

Financial Statements

Financial statements must comply with international or local accounting standards.

Documents Confirming Control

Such documents may include:

• corporate charters;
• agreements;
• meeting minutes;
• shareholder resolutions;
• powers of attorney;
• other documents confirming managerial influence.

Additional Supporting Documents

Tax authorities may additionally request:

• banking documents;
• corporate records;
• proof of financial transactions;
• group structure documentation.

Where Should CFC Reporting Be Submitted?

Reports are submitted to the State Tax Service of Ukraine via:

• the taxpayer’s electronic cabinet;
• other official electronic communication channels.

The CFC report is submitted together with the annual tax declaration for the relevant tax year.

Generally:

• the filing deadline is May 1 of the year following the reporting year.

Practical Recommendations

Prepare Documents in Advance

Collect and organize documentation before the end of the tax period to avoid mistakes and delays.

Work with Legal and Tax Professionals

Professional support significantly reduces the risk of penalties and reporting errors.

Properly Document Control Structures

A transparent ownership and control structure is critical for successful compliance.

Verify Financial Information Carefully

Dormant or loss-making companies must still be accurately disclosed.

Use Official Electronic Platforms

Submit reports only through official electronic systems to avoid technical rejections.

Respond Promptly to Tax Authority Requests

Any additional document requests should be addressed without delay.

Why Is Legal Support Important?

CFC reporting is part of international tax compliance and corporate transparency requirements.

The Ukrainian Bar and Real Estate Association provides comprehensive assistance, including:

• foreign corporate structure analysis;
• CFC reporting preparation;
• legal support during submission procedures;
• tax audit support;
• representation in disputes with tax authorities.