On 11 January 2024, the State Tax Service of Ukraine, in a release announced it has introduced Country-by-Country (CbC) reporting for the parent companies of the international groups of companies for the first time in the country. The CbC reporting requirements will apply from the 2022 reporting financial year. It is part of the three-level structure of documentation on transfer pricing, which was introduced in Ukraine in 2020.
This reporting model is recommended by the Organization for Economic Cooperation and Development (step 13 of the BEPS Action Plan) to implement comprehensive control over operations within international groups of companies and create favorable conditions for doing business in Ukraine. The CbC reports submission deadline was 1 January 2024.
CbC Reports were submitted by 6 taxpayers who are the parent companies of the international groups of companies as of 2 January 2024 and are active in various fields such as electricity, oil and gas, agriculture, financial services, railway transportation, and trade.
The total number of participants in the international groups of companies is 152 companies, of which only 14 (or 9 percent) are not residents of Ukraine. It should be emphasized that control over submission of the CbC Reports by taxpayers – residents of Ukraine, completeness and reliability of provided information is carried out by the State Tax Service of Ukraine, taking into account provisions of Sub-paragraphs 39.4.10 – 39.4.15 of Paragraph 39.4 Article 39 of the Tax Code of Ukraine.
