A new form of the country-by-country report for international groups of companies has been approved

The Order of the Ministry of Finance of Ukraine dated 14.12.2020 №764 (hereinafter - the "Order") approved the form of the country-by-country report of the international group of companies (hereinafter - the "CbCR"). The Order entered into force on 19 February 2021. 

The CbCR must be submitted if the international group of companies has a total consolidated group revenue of more than EUR 750 million during the fiscal year preceding the reporting fiscal year, along with other circumstances.

The requirement for CbCR submission is firstly applied to the financial year ending in 2021, but not earlier than the year in which the competent authorities joined the multilateral agreement on the automatic exchange of interstate reports (Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports).

The form of the CbCR contains the following parts:

1. General information about the CbCR, the taxpayer, the name of the international group of companies and the reporting period

2. Separate reports for all separate countries (territories) in which the international group of companies operates, which contain information on the allocation of income, taxes and business activities of the international group of companies. Each report contains information on the list of all constituent entities of the international group of companies included in each particular state (territory) as well as:

• the name of the state (territory) of registration
• total amount of income (revenue), including a breakdown into separate agreements
• the amount of accrued and paid corporate income tax (corporate tax)
• the amount of the stated capital
• the amount of retained (accumulated) earnings
• number of employees
• book value of tangible assets
• main business activities performed by all entities of the international group of companies.

3. Additional information - any brief information or explanations that the taxpayer considers necessary or that would facilitate the understanding of the mandatory information provided in the CbCR.

PwC experts are ready to provide more details regarding the abovementioned CbCR and its necessity for transfer pricing purposes.