The State Tax Service of Ukraine issued a guidance letter (No. 1308/IPK/99-00-21-02-03 IPK)  on 12 March 2025 regarding the requirement for Ukrainian entities to submit a Country-by-Country (CbC) report on behalf of their US-based parent multinational group.

This report would cover the fiscal year from 1 September 2024 to 31 August 2025.

The guidance clarifies that, for the first time, the secondary local filing requirement will apply to fiscal years starting on or after 1 January 2024. This is because the Country-by-Country Multilateral Agreement (MCAA) became effective for Ukraine on 4 July 2024.

Under the new rules, secondary local filing is necessary if specific conditions are met. These conditions include having a valid international agreement for the exchange of tax information between Ukraine and the parent company’s country, but without a competent authority agreement for exchanging CbC reports in place by the end of the reporting year.

The 1994 Ukraine-US tax treaty qualifies as such an agreement. While the US has not yet signed the CbC MCAA, negotiations for a bilateral CbC Competent Authority Agreement (CAA) are ongoing. Because this CAA is not yet in effect, Ukrainian entities will need to comply with the secondary local filing requirements.

For the fiscal year ending 31 August 2025, the deadline for submitting the CbC report is set for 31 August 2026.

Earlier, 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 on 11 January 2024,. 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.