On 19 February 2021, the Ukrainian Ministry of Finance (MOF) has issued a press release where they clarify the procedure for submitting Country-by-Country (CbC) report.

The Order of the Ministry of Finance No. 764 dated 14 December 2020, which approved the form and procedure for CbC report came into force.

The Report is submitted if the total consolidated income of the international group of companies, part of which is the taxpayer, for the fiscal year preceding the reporting year, calculated in accordance with the accounting standards applied by the parent company of the international group (in the absence of information – in accordance with International Financial Reporting Standards) exceeds the equivalent of EUR 750 million.

At the same time, the report is prepared for the fiscal year determined by the parent company of the international group of companies, which may not coincide with the calendar year.

It also provides that the submission by taxpayers of CbC Report for the first time applies to the fiscal year that ends in 2021, but not earlier than the year in which the Multilateral Competent Authority Agreement on the Exchange of CbC reports was concluded.

The introduction of the CbC report will allow the Ukrainian tax authorities receiving comprehensive information (including information exchange procedures for tax purposes after the introduction of such exchange) on the activities of international groups of companies in terms of specific jurisdictions, and to carry out effective analysis of the scope of activities, the structure of operations and specifics of the activities of international groups of companies for the purposes of control over transfer pricing.

Note that the CbC report must be submitted within 12 months after the end of the fiscal year of the group, and 2021 is the first reporting period, but not before Ukraine joined CbCR MCAA.