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REPORTING ON CONTROLLED FOREIGN COMPANIES (CFC)

We provide full support in preparing and submitting reports on controlled foreign companies in accordance with the Tax Code of Ukraine. We guarantee the accuracy of calculations, compliance with deadlines, risk minimization and data confidentiality. We work with individuals and legal entities, helping to fulfill the requirements of the CFC without penalties and unnecessary time spent.
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OLEG IVCHENKO

UKRAINIAN ASSOCIATION OF VALUATION SPECIALISTS (PUAVS)
Authorized by the
WORLD ASSOCIATION OF VALUATION ORGANIZATIONS (WAVO)

Over 15 years of experience
Hello,
I’m Oleh Ivchenko — a certified valuer, founder and managing director of Pareto Consulting Group and the Wise Group (a patent and legal advisory firm). With over 15 years of hands-on experience in valuing companies, assets, enterprises, and intangible property of any complexity, I deliver insights at the intersection of finance, law, and analytics.

Clients come to me when the stakes are high — when results must be accurate, defensible, and trusted by international auditors, banks, and regulatory bodies. My expertise includes business valuation, transfer pricing advisory, CFC reporting, IFRS-compliant audit support, and tax consulting focused on risk mitigation and legal optimization.

This website is my personal platform to communicate openly with business leaders. If you're looking for an expert who sees more than just numbers — someone who understands context, strategy, and value — you're in the right place.

Trust expertise. Move forward with confidence.
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In what cases are CFC reporting services required?

  • If you are the owner or controller of a foreign company

  • When preparing the first reporting on CFC under the new rules

  • If necessary, avoid penalties for missed deadlines or errors in the report

  • To confirm the transparency of the business structure before tax authorities

And also for any other of your goals and needs!

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What is a CFC and who is required to file reports on controlled foreign companies?

A controlled foreign company (CFC) is a legal entity or other entity registered outside Ukraine that is controlled by a tax resident of Ukraine. According to the Tax Code of Ukraine, reporting on CFCs is required to be submitted by all controllers who:
  • directly or indirectly own more than 50% of a foreign company;
  • have from 10% (from 2023), if the total share of all residents of Ukraine exceeds 50%;
  • exercise actual control over the company (manage, sign contracts, have access to bank accounts).
Filing of CFC reporting in Ukraine is mandatory for both active and "dormant" companies, unless they are officially liquidated.

When to file CFC reports in 2025?

Deadlines for submitting reports on controlled foreign companies in Ukraine:
  • Individuals - by May 1, together with a declaration of property status and income.
  • Legal entities - by March 1, together with a corporate income tax declaration.
The law requires reporting on the acquisition or loss of control over a CFC within 60 days.

What documents are required for filing CFC reports in Ukraine?

The package of documents includes:
  • financial statements of the CFC according to IFRS or standards of the country of registration;
  • calculation of adjusted profit;
  • information on dividends, passive income, transactions with representative offices in Ukraine;
  • confirmation of tax payment abroad (for applying benefits);
  • audit report (in certain cases);
  • certified translations of documents in a foreign language.
All CFC reporting is submitted electronically from the CEP through the Taxpayer's Electronic Cabinet.

What is the tax rate on CFC and can double taxation be avoided?

The tax rate for controlled foreign companies in Ukraine is 18% of adjusted profit. Reduced rates are available for individuals — 5% or 9% depending on the type of income, plus a military levy of 1.5%.
Exemption from taxation of CFC is possible if:
  • the company's annual income is less than 2 million UAH;
  • tax is paid in the country of registration at an effective rate of 13%;
  • passive income is less than 50% of the total;
  • the company is public, charitable or trust without income distribution.

What is the liability for failure to report on CFC?

  • 302,800 UAH (100 PM) — for failure to submit a report;
  • 151,400 UAH (50 PM) — for failure to submit a notification about the CFC;
  • 30,280 UAH — for understating profit;
  • 3% of the adjusted profit — for intentionally submitting false data.
During martial law, fines for late payment do not apply, but the obligation to submit a report remains.

How do we help with the preparation and submission of CFC reporting?

We provide a full range of CFC services in Ukraine:
  • determination of controller status;
  • analysis of company structure and tax risks;
  • calculation of adjusted profit;
  • preparation and submission of electronic CFC reporting;
  • support during State Tax Service inspections.

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