CFC for Ukrainians: reporting Controlled Foreign Companies

Owners of foreign companies file a CFC report each year, even if there was no activity. Late filing means fines in the hundreds of thousands of hryvnia.

Who is obliged

Residents of Ukraine with a share above 50% in a foreign entity (or 10% under certain conditions). Also de facto controllers, even without a formal share.

Fixing past periods

Better to file a clarifying report now than wait for a request from the tax service. In most cases the consequences are manageable.