Turnkey CFC reporting preparation and filing in Ukraine
We prepare a complete CFC report: structure analysis, adjusted profit calculation, document preparation, and full support for submission to the Ukrainian tax authorities within the required deadlines
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What is a CFC (Controlled Foreign Company)?
A Controlled Foreign Company (CFC) is a foreign legal entity or other structure controlled by a tax resident of Ukraine. In such cases, the controller must submit an annual CFC report (CFC reporting) to the Ukrainian tax authorities together with their разом із tax return declaration. The reporting obligation applies even if the company did not generate any profit.
Who must file a CFC report
The reporting obligation arises if you own a share in a foreign company or exercise actual control over its activities, including the following cases:
Not sure if your case falls under CFC rules?
We assess your controller status and determine if CFC reporting is required
What documents and information are required for CFC reporting
To prepare a CFC report without errors and reduce the risk of penalties, you need to provide key information about the company, its financial data, and the controller
Company registration details
Company name, country of registration, address, tax and registration numbers, ownership structure, and share percentage
Financial statements
Certified copies of financial statements, translated into Ukrainian if required (translation is not needed if the report is already in English)
Operations and transactions
Information on transactions with related parties and counterparties from the lists approved by the Cabinet of Ministers (required to complete relevant sections of the report)
Controller information
Passport, tax number, and information about personal income and tax reporting
If some documents are missing or information needs clarification, we will help collect, restore, and prepare all required data for CFC reporting
Have questions about CFC reporting? Get a consultation
Types of CFC reports: simplified and full. Filing requirements
Ukrainian tax residents submit either a simplified or a full CFC report, depending on whether financial statements are available at the time of filing the tax return. When submitting a full report, the adjusted profit calculation may be included or not, depending on financial indicators and applicable tax exemptions.
Below is a brief explanation of each report type.
A simplified CFC report is filed if the controlled foreign company carried out activities but does not yet have financial statements as of April 30. It is submitted by individuals and legal entities — Ukrainian tax residents who control foreign companies but cannot file a full CFC report due to unavailable financial statements at the time of tax filing. The simplified report is submitted within the same deadlines as the main tax return.In this case, the full report can be filed later, until December 31 of the same year.
A full CFC report is filed by April 30 if the foreign company has financial statements available by that date. If a simplified report was submitted earlier, the full report must be filed by the end of the calendar year. If the total income of all CFCs of one controller does not exceed EUR 2 million, or other exemption conditions apply, tax on adjusted profit is not charged.
When should a CFC report be submitted?
A CFC report is submitted in the year following the end of the financial year of the controlled foreign company. Below are examples of reporting deadlines depending on the year the company was registered.
| Company registration year | CFC reporting deadline |
|---|---|
| 2025 | The CFC report must be submitted in 2026 or 2027, depending on the closing date of the first financial year. |
| 2024 | The CFC report must be submitted in 2025 or 2026, depending on the closing date of the first financial year. |
| 2023 | The CFC report must be submitted in 2024 or 2025, depending on the closing date of the first financial year. |
| 2022 | The CFC report must be submitted in 2024 with reporting for 2023. |
CFC reporting period, if the financial year is not calendar-based
Need help with CFC reporting?
Get a free consultation on the preparation and filing of a CFC report for your specific case
How to prepare and submit a CFC report: stages and timelines
The time required to prepare a CFC report depends on the company’s jurisdiction, the CFC structure, the availability of financial statements, and the completeness of the documents. If all the necessary data is already prepared, the process usually takes from 3 to 7 business days. Below are the main stages of preparing and submitting a CFC report
Cost and packages for CFC report preparation
Choose the format based on the availability of financial statements: a simplified or a full CFC report. The cost of preparation and filing starts from €150. Additional formats (zero report or report with adjusted profit calculation) are available upon individual request
Simplified report
Suitable if the foreign company’s financial statements are not available at the time of filing the tax return.
- Initial consultation (30 min)
- Preparation and filing of the personal income and assets declaration
- Preparation and submission of CFC appendices to the tax declaration
- Preparation and submission of a simplified CFC report
- Filing confirmation and basic support
Full report
Suitable if financial statements are available or a full report must be submitted.
- Initial consultation (30 min)
- Preparation and filing of the personal income and assets declaration
- Preparation and submission of CFC appendices to the tax declaration
- Support with document collection and certification
- Coordination of document translation into Ukrainian
- Preparation and submission of a full CFC report (company with turnover)
- Filing confirmation and basic support
We will help you choose the CFC report format and calculate the cost
Your consultant
Ivan Chebotarov
CEO & co-Founder
Get a consultation on CFC reporting
We respond within one business day.
We will advise on the CFC report format and estimated cost
CFC reporting in Ukraine: Frequently asked questions (2026)
How to submit a CFC report to the Ukrainian tax authorities?
A CFC report is submitted to the State Tax Service of Ukraine via Taxpayer’s Electronic Cabinet.
Submission is made electronically using a qualified electronic signature (QES) or Diia.Signature.
The CFC reporting package includes:
– CFC report (Form F0108701)
– Annual personal income and assets declaration (Form F0100214)
– CFC appendix with tax liability calculation (Form F0121814)
– Additional documents or explanations (if required)
All documents are submitted as a single package together with the annual declaration..
What should you do if some CFC documents are missing?
If some documents or financial data are missing, it does not mean that the report cannot be prepared.
Possible options:
– submitting a simplified CFC report
– preparing alternative profit calculations
– reconstructing financial data based on available information
– preparing explanations for the tax authorities (if required)
We help assess the available data and choose the safest reporting format.
What penalties apply for non-submission or errors in CFC reporting in 2026?
In 2026, the following penalties apply for violations of CFC reporting requirements:
– Failure to submit a CFC report — approximately UAH 332,800 (100 subsistence minimums).
– Late submission — 1 subsistence minimum for each day of delay, but not more than UAH 166,400.
– Incomplete or inaccurate information 3% of undisclosed transactions or 25% of the adjusted profit, but not more than UAH 3,328,000.
The actual amounts depend on the subsistence minimum set for the relevant year.
More details on penalties and calculation examples are available in our article on CFC sanctions..
When is a zero CFC report or an adjusted profit report required?
Zero CFC report
Submitted if the foreign company had no activity or no income during the reporting period. The amount of information is minimal, but the reporting obligation may still apply.
CFC report with adjusted profit
Required when the taxable profit of the CFC must be calculated according to Ukrainian tax rules. Applies if the company has a turnover or does not meet the exemption conditions.
When does CFC taxation apply, and when is it not required?
The controller may be required to pay tax on the adjusted profit of a controlled foreign company.
At the same time, in many cases, no tax liability arises.
Exemption from CFC taxation applies if:
– the total annual income of all CFCs of one controller does not exceed EUR 2 million;
– the company earns mainly active income (more than 50%);
– the company has real economic substance in the country of incorporation;
– corporate tax in the country of registration is paid at an effective rate of at least 13%.
Can errors in a CFC report be corrected after submission?
Yes. If an error is identified after submission, an amended (corrected) CFC report may be filed with updated information and, if required, revised attachments or supporting documents. We will help determine which data needs correction and prepare the full package for resubmission via the taxpayer’s electronic cabinet.
Does sole proprietor status or living abroad affect the obligation to submit a CFC report?
Not always. CFC reports are filed by Ukrainian tax residents who act as controllers of a foreign company (CFC). If you operate as a sole proprietor (individual entrepreneur) abroad and do not control any foreign companies, a CFC report is generally not required. However, if you remain a Ukrainian tax resident and own or control a foreign company, CFC reporting obligations may apply.
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