Mark the new deadline for Transfer Pricing in your calendar

After October 1, most taxpayers breathed a sigh of relief — the usual transfer pricing (TP) reporting campaign for 2024 in Ukraine has ended.

However, for some companies, reporting is not finished yet. A new deadline is approaching: December 31, 2025. By this date, many taxpayers must submit the Country-by-Country Report (CbCR).

CbCR is part of the three-tiered TP reporting structure and applies to groups with consolidated revenue of €750 million or more for the previous financial year. This year, a wide range of groups are required to submit the CbCR to the Ukrainian tax authorities.

Important to remember: failure to submit CbCR by a Ukrainian taxpayer will result in a penalty of UAH 3,028,000 – equivalent to 1,000 times the statutory subsistence minimum as of January 1, 2024.

In the latest announcements, the tax authorities state that all Ukrainian taxpayers belonging to an international group whose ultimate parent company is registered in the USA, Canada, or Israel must submit CbCR in Ukraine for 2024.

The tax authorities are actively providing individual tax consultations on the submission of CbCR and, according to recent clarifications, their position is becoming increasingly strict: in most cases, the CbCR must be submitted in Ukraine.

At the same time, the Tax Code of Ukraine provides certain exceptions and circumstances under which a Ukrainian taxpayer may be exempt from submitting CbCR.

Our team is ready to answer all your questions, conduct an individual analysis of whether CbCR filing is required (including identifying potential risks), or assist with preparing the CbCR.