Ukraine requires annual CFC reports, with penalties waived during martial law if filed within six months after it ends.
Ukraine’s State Tax Service (STS) has clarified that, under the country’s controlled foreign company (CFC) rules, a controlling person is required to file an annual CFC report.
This announcement was made by STS on 1 September 2025.
Failure by a controlling entity to submit a report on controlled foreign companies results in a fine of 100 times the subsistence minimum for able-bodied persons established by law as of 1 January of the tax (reporting) year.
Late submission by a controlling entity of a report on controlled foreign companies results in a fine of one subsistence minimum for able-bodied persons established by law as of 1 January of the tax (reporting) year for each calendar day of non-submission, but not exceeding 50 times the subsistence minimum for able-bodied persons established by law as of 1 January of the tax (reporting) year.
At the same time, the Law of Ukraine dated 4 December 2024 No. 4113-IX “On Amendments to the Tax Code of Ukraine and Other Laws of Ukraine to Promote the Development of the Digital Economy in Ukraine” amended paragraph 72 of subsection 10 of section XX of the TCU, providing that for violations committed from 1 January 2022 and during the period of martial law in Ukraine, introduced by the Decree of the President of Ukraine “On the Introduction of Martial Law in Ukraine” dated 24 February 2022 No. 64/2022, approved by the Law of Ukraine “On Approval of the Decree of the President of Ukraine ‘On the Introduction of Martial Law in Ukraine’” dated 24 February 2022 No. 2102-IX, up to the last calendar day (inclusive) of the calendar month in which martial law is terminated or lifted, penalty sanctions shall not apply to taxpayers for violations provided for in the first through eighth subparagraphs of paragraph 120.7 of Article 120 of the TCU, provided that the controlling entity fulfills the obligations set out in Article 39, note 2 of the TCU within six months after the termination or lifting of martial law.
Thus, penalty sanctions will not apply to a controlling entity for violations committed from 1 January 2022 and during the period of martial law in Ukraine, up to the last calendar day (inclusive) of the calendar month in which martial law is terminated or lifted, provided the controlling entity fulfills the obligations under Article 39, note 2 of the TCU within six months after the termination or lifting of martial law.
