WHAT IS THE DEADLINE FOR SUBMITTING THE REPORT ON CONTROLLED FOREIGN COMPANIES IN UKRAINE? WHAT DOCUMENTS ARE ATTACHED TO THE REPORT?

The reporting period for submitting CFC reports to the tax authorities begins on January 1, 2023.

For the purposes of tax control over the taxation of profits of a controlled foreign company, the reporting (tax) period is the calendar year or another reporting period of the controlled foreign company ending within the calendar year.

Controlling persons are obliged to submit a report on controlled foreign companies to the controlling body simultaneously with the submission of the annual declaration on property status and income or the tax declaration on the income tax of enterprises for the relevant calendar year by means of electronic communication in electronic form in compliance with the requirements of the law on electronic document flow and qualified electronic signature.

The report on controlled foreign companies must be accompanied by certified copies of the CFC’s financial statements, which confirm the amount of the CFC’s profit for the reporting year.

If the deadline for preparing financial statements in the relevant foreign jurisdiction is later than the deadline for submitting an annual declaration of assets and income or a tax return on corporate income tax, such copies of the financial statements of the CFC shall be submitted together with the annual declaration of assets and income or a tax declaration with corporate income tax for the next reporting (tax) period.

The report is filed regardless of whether the adjusted income of the CFC is exempt from taxation. The first report can be submitted in 2024 immediately for 2022 and 2023.