CFC Reporting

Residents who directly or indirectly own or exercise actual control over a foreign company. We assess ownership shares, related‑party agreements and signs of control in your structure.

Incorporation documents, ownership structure, the CFC’s financial statements, account statements, contracts, related‑party transactions, the tax status of the jurisdiction, and proof of genuine activity.

We evaluate not only the formal share but also the ability to influence decisions, manage accounts, appoint directors, issue binding instructions to management, etc. We prepare an analytical memorandum with our conclusion.

We take the financial result under the CFC’s accounting standards and adjust it according to the requirements of the Tax Code of Ukraine. We coordinate the approach with your accountant/auditor and prepare the calculation with references to data sources.

Yes, exceptions may apply (for example, active business, certain income thresholds, the existence of double tax treaties, effective tax rate requirements). We check the conditions and collect supporting evidence.

Deadlines are tied to the filing of the resident’s annual returns. Significant penalties apply for violations. We manage deadlines and prepare an action plan to avoid sanctions.