We analyse the ownership structure, financial data and available documents, determine the sequence of actions and help align the reporting with the requirements of Ukrainian legislation.
The service is intended for owners of foreign businesses, co-owners of international companies and persons who effectively manage their activities. We assist if you have recently established or acquired a company abroad, are preparing your first CFC report, are changing the ownership structure or need previously submitted documents to be reviewed.
Prikhodko & Partners analyses your situation, determines the list of required documents and explains which actions must be taken and in what sequence. We compare corporate information with financial indicators, clarify data with your accountant and review the package before submission.
You receive a clear work plan, an agreed scope of support and assistance with preparing the documents. This makes it possible to identify discrepancies in advance, reduce repeated follow-up requests and organise reporting without having to deal with every procedural issue independently.
The service is intended for owners and co-owners of foreign companies who are preparing their first report, changing their business structure or reviewing previous submissions. We begin by analysing tax residence, direct and indirect ownership and actual management. We take into account changes during the reporting period and determine which documents need to be prepared.
During the consultation, we distinguish between the annual report and the CFC notification relating to the acquisition or cessation of control and other events defined by law. Submission of one document does not replace the other. We separately review the deadlines for the relevant year and category of taxpayer.
We agree on the channel for transferring documents, discuss the situation remotely and determine the next steps. For the preliminary assessment, a description of the structure and the available documents are required. There is no need to provide passwords or personal electronic signature keys.
We provide assistance before the first reporting and after changes in the business:
A separate report is submitted for each CFC together with the relevant annual tax return of the controlling person. Exemption of profit from taxation does not remove the obligation to submit a report. The foreign company’s financial year must also be aligned with the Ukrainian reporting period.
Properly certified copies of the financial statements are attached to the full report. If the foreign deadlines for preparing them are later, the procedure for providing the copies is reviewed separately under the Tax Code of Ukraine.
| Work stage | What we review | Possible documents | Result |
|---|---|---|---|
| Control analysis | Ownership interests and authority | Extracts, articles of association, agreements | Determination of obligations |
| Financial review | Period and indicators | Financial statements, breakdowns | Data for the report |
| Preparation for submission | Form and details | Report, tax return, attachments | Agreed package |
An error in determining the controlling person or the relevant period may affect several documents at once. Therefore, we compare registry data, financial indicators and authority. More information about support for controlled foreign companies is available on a separate service page.
Where there are links with several countries, we additionally analyse tax residence. A useful resource is how to obtain a Ukrainian tax residence certificate. Risks of an international structure are also considered in the article “Offshore Does Not Mean Protection: What Do Banks Actually Check?”.
Preparing CFC reporting requires coordinated work with corporate documents, financial indicators and the controlling person’s data. By contacting Prikhodko & Partners, you receive assistance at every agreed stage: from determining obligations and collecting information to reviewing documents and supporting submission.
We explain the requirements in clear language, draw attention in advance to missing documents and inconsistencies and help organise interaction with the accountant. Submit a request — we will review your business structure, determine the priority tasks and propose a scope of support appropriate to your situation.
A CFC is a foreign legal entity controlled by a Ukrainian tax resident. In cases defined by law, the rules also cover arrangements without legal personality. The report discloses information about the company, control and financial indicators.
The obligation does not apply only to offshore businesses. Lack of activity, a loss or exemption of profit from taxation also do not in themselves remove the reporting obligation.
The report is submitted by the controlling person — a resident of Ukraine. Under the general rules, this is a person with an interest exceeding 50%, or exceeding 10% if Ukrainian residents collectively own 50% or more. A separate ground is actual control exercised independently or jointly with related persons who are Ukrainian residents.
Therefore, the interests and authority of each co-owner are assessed. One controller’s report does not automatically replace another controller’s report; at the same time, the law provides exceptions for ownership through a Ukrainian legal entity that itself fulfils the controller’s obligations.
No. The simplified form is submitted when it is impossible, by the tax return deadline, to ensure preparation of the CFC’s financial statements and/or calculation of adjusted profit. It contains limited information and does not replace final reporting.
Afterwards, a full report must be submitted by the end of the calendar year: for reporting for 2025 — by 31 December 2026. If the full report increases taxable income or the taxable base, the obligation to submit an amended tax return should also be reviewed.
No. A statement shows the movement of funds but does not replace financial statements: an incoming payment is not always income, and an outgoing payment is not always an expense of the relevant period. Information about owners, interests, financial indicators and company transactions is also required. Where necessary, we request breakdowns and information about dividends and taxes.
If the financial statements have not yet been prepared, we determine the procedure for preparing them with the accountant and review the grounds for a simplified report. Requirements concerning certification, format and the deadline for providing documents are assessed separately.
It is advisable to seek advice when the company is established or acquired: notification of the relevant events and the annual report have different deadlines. For the first report, the company’s financial period, which may be extended, should also be taken into account.
If the deadline has been missed, the unsubmitted documents, periods and correction procedure are determined. The consequences are assessed under the rules applicable to the relevant period, taking into account current transitional provisions, rather than solely by reference to the general amount of the penalty.
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Describe the taskKyiv City, 2 Mechnikova Street, Business Center "Parus", 10 th floor
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Kyiv City, 2 Mechnikova Street, Business Center "Parus", 10 th floor
Kyiv City, 2 Mechnikova Street, Business Center "Parus", 10 th floor
Kyiv City, 2 Mechnikova Street, Business Center "Parus", 10 th floor
Kyiv City, 2 Mechnikova Street, Business Center "Parus", 10 th floor
Founder of the company
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