State Tax Service (STS) of Ukraine clarifies on Country-by-Country Reporting Requirements for MNE Group Participants
03/10/25
The State Tax Service (STS) of Ukraine has provided new individual tax rulings (ITR) regarding the obligation for multinational enterprise (MNE) group participants to submit Country-by-Country (CbCr) Reports.
In particular, ITR No. 4132/IPK/99-00-21-02-03 dated 31 July 2025, states that, since the Qualifying Competent Authority Agreement (QCAA – bi- or multilateral agreement on the exchange of CbCR) between the foreign jurisdiction of the parent company’s registration and Ukraine has not taken effect as of the end date of the financial year starting between 1 January and 31 December 2024, the taxpayer is obliged to submit the CbCR for the specified financial year in Ukraine.
However, if the parent company appoints another member of the MNE group to submit the CbCR in a jurisdiction that has an effective international agreement with Ukraine containing provisions for tax information exchange, and the QCAA has also entered into force, such taxpayer may be exempt from submitting the CbCR, provided all conditions stipulated in subparagraph 39.4.101 are simultaneously met (provided that such CbCR is not submitted merely in accordance with the tax legislation requirements of the registration jurisdiction of that other group member).
Furthermore, ITR No. 4470/IPK/99-00-21-02-03 dated 20 August 2025 addresses the need to submit the CbCR when the taxpayer does not perform controlled transactions. The tax authority notes that subparagraph 39.4.10 of Article 39 of the Tax Code of Ukraine does not provide an exemption from the submission of a CbCr by taxpayers who have not engaged in controlled transactions. Therefore, if an IGC’s consolidated income exceeds EUR 750 million and a valid international agreement on information exchange exists between Ukraine and the parent company’s jurisdiction—but the relevant QCAA agreement is not yet in effect—the Ukrainian resident taxpayer is required to file the CbCr.
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