Ukrainian Tax Authority has received the first Country-by-Country reports ("CbCr") from 21 foreign jurisdictions as part of the automatic exchange of information.
The Tax Authority emphasizes, "In the absence of a valid Qualified Competent Authority Agreement (QCAA) with the jurisdiction of tax residency of the parent company, the CbC report for 2024 must be filed independently by the Ukrainian resident."
As of December 31, 2024, the relevant QCAA agreement had not entered into force with, among others, the United States, Canada, and Israel. Therefore, the Tax Authority opines that if a Ukrainian company is part of an international group, and the ultimate parent entity is registered in the United States, Canada, or Israel, such a taxpayer must file the CbCr for 2024 independently.
Failure to file, late filing, or submission of inaccurate information in CbC reports or Notifications of participation in IGC is subject to penalties under Article 120 of the Tax Code of Ukraine.
Refer to the provided link to verify the current status of automatic exchange relationships. Note that exchange relationships are not always bilateral.
For further inquiries, please contact our experts.
