The automatic exchange of reports with these countries have not yet fully worked as of the end of 2024.
The State Tax Service of Ukraine announced that constituent entities in Ukraine belonging to multinational enterprise (MNE) groups headquartered in the US, Canada, or Israel are required to submit Country-by-Country (CbC) reports in Ukraine for the 2024 reporting period.
This announcement was made by the State Tax Service of Ukraine on 2 July 2025.
The reason is that the automatic exchange of reports with these countries has not yet fully worked as of the end of 2024.
As a part of the international cooperation in the tax control and transfer pricing spheres, Ukraine participates in the automatic exchange of the country-by-country reports (CbC – Country-by-Country Reporting). It officially entered into force on 4 July 2024.
Ukrainian companies that are part of the international group of companies must submit the CbC report in cases when:
- Parent company is registered in a country with which international tax information exchange agreement has been signed,
- Relevant automatic exchange agreement (QCAA) has not yet entered into force as of 31 December 2024.
As of the end of 2024, such an agreement was not yet in force with the US, Canada and Israel.
