Ukraine’s president, Volodymyr Zelensky has signed Law No. 9319 on 25 December 2024 which postpones a new military tax hike for small businesses and individual taxpayers until 1 January 2025. Under this law, Ukrainian residents will not be fined for failing to submit or delaying reports on controlled foreign companies (CFC) until the martial law is suspended.

However, taxpayers must meet their obligations within six months after martial law ends.

Administrative and criminal penalties for related violations will not be enforced except for banking institutions.

Obligation for a CFC in Ukraine

  1. Inform the Ukrainian tax authorities regarding the establishment of a foreign company or the acquisition of a share in such a company;
  2. Submit annual financial statements of the CFC along with a tax return;
  3. In the absence of a tax exemption, remit taxes on the CFC annually;
  4. Inform the Ukrainian tax authorities about the formation of a trust or fund;
  5. Notify the tax authorities of Ukraine regarding the dissolution of the company/trust or the sale of a share in it.