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Controlled Foreign Companies: Reporting for 2025

Updated: November 2026
 
On 1 January 2022, Law of Ukraine No. 466-IX of 16 January 2020 took effect. It amended the Tax Code of Ukraine and introduced rules on the taxation of controlled foreign companies (CFCs). Detailed analysis of the Law as of its adoption.
 
Who is a controlling person
A foreign company or an entity without legal personality, such as a trust, foundation or partnership, is a controlled foreign company if an individual or legal entity resident in Ukraine:
  • holds more than 50%;
  • holds more than 10%, where Ukrainian residents together hold 50% or more;
  • exercises actual control over the company, alone or together with related persons.
When CFC profit is exempt from tax
The adjusted profit of a CFC is not taxed in Ukraine if:
  • the total income of all CFCs of the controlling person for the reporting year does not exceed the equivalent of EUR 2 million;
  • the CFC is registered in a state that has a double tax treaty or an information exchange agreement in force with Ukraine, and either pays corporate income tax at an effective rate of at least 13% or derives no more than 50% of its total income from passive income;
  • the CFC’s shares are traded on a recognised stock exchange;
  • the CFC is a charitable organisation that does not distribute income among its founders.
An exemption from tax does not release the controlling person from the obligation to file a CFC report.
 
Tax rates
For legal entities, the adjusted profit of a CFC is subject to corporate income tax at 18%.
 
For individuals, it is subject to personal income tax at 18%, or 9% if the profit is distributed as dividends before the report is filed, plus military levy. The tax is reduced by the corporate income tax actually paid by the CFC, in proportion to the controlling person’s share.
 
CFC report
Since 1 January 2024, all controlling persons, both individuals and legal entities, must file a report on their controlled foreign companies. Our offer for preparing CFC reporting.
Deadlines for the 2025 report:
  • individuals — by 1 May 2026, together with the annual property and income tax return (in Ukrainian);
  • legal entities — by 1 March 2026, together with the corporate income tax return.
The report may be full or short.
 
The full report is filed together with the tax return, the CFC annex to the return and the financial statements of the foreign company translated into Ukrainian. No translation is required if the statements are prepared in English. Full report form (in Ukrainian).
 
A short report is filed if the CFC’s financial statements have not yet been filed in the relevant foreign jurisdiction at the time of reporting. In that case, the full report for 2025 must be filed by 31 December 2026. Short report form (in Ukrainian).
 
The report is filed electronically with a qualified electronic signature through the taxpayer’s electronic cabinet, with the tax authority at the resident’s main place of registration.
 
Notice of acquiring or ending participation in a CFC
Under subparagraph 39².5.5 of the Tax Code of Ukraine, an individual or legal entity resident in Ukraine must notify the tax authority of:
  • each direct or indirect acquisition of a share in a foreign legal entity, or the start of actual control over it, that makes the resident a controlling person;
  • the establishment, creation or acquisition of property rights to a share in the assets, income or profit of an entity without legal personality;
  • each disposal of a share in a foreign legal entity, or the end of actual control over it, that results in losing controlling person status;
  • the liquidation of, or disposal of property rights to a share in the assets, income or profit of, an entity without legal personality.
The notice is filed within 60 days of acquiring the share (or starting actual control) or disposing of it (or ending actual control), electronically through the taxpayer’s electronic cabinet.
 
The notice form is approved by Order of the Ministry of Finance of Ukraine No. 512 of 22 September 2021, registered with the Ministry of Justice of Ukraine on 22 November 2021 under No. 1525/37147. Notice form (in Ukrainian).
 
Penalties
Under subparagraph 72 of subsection 10 of section XX of the Tax Code of Ukraine, penalties for breaches of the CFC rules do not apply to breaches committed from 1 January 2022 until the last day of the month in which martial law is terminated or lifted. The condition is that the controlling person files the reports and notices within six months after martial law ends. This rule was introduced by Laws of Ukraine No. 3706-IX of 9 May 2024 and No. 4113-IX of 4 December 2024.
 
The waiver covers penalties for failing to file or late filing of a CFC report, incomplete information in the report, and failure to file a notice of acquiring or disposing of a share.
 
Our services
  • Determining controlling person and CFC status, including actual control and holdings through trusts or foundations.
  • Analysing grounds for exempting CFC profit from tax.
  • Calculating the adjusted profit of a CFC and the tax payable, taking into account tax paid abroad.
  • Preparing full and short CFC reports and notices of acquiring or disposing of shares.
  • Obtaining individual tax rulings on CFC matters and representing clients in disputes with the State Tax Service.
Useful materials