Who is a controlling person
Only a Ukrainian tax resident. TCU Art. 39-2 makes no exception for foreigners.
| Duty | Deadline | Penalty in 2026 |
|---|---|---|
| Notification | 60 days after acquiring or disposing of an interest or control | 300 subsistence minimums (UAH 998,400) per failure |
| Annual CFC report | With the annual return, by May 1 | 100 subsistence minimums (UAH 332,800) |
Martial law
Law No. 4113-IX: no penalties for violations from January 1, 2022 through the month martial law ends, provided you comply within six months afterward. Reporting duties and tax remain.
Exemptions
CFC profit is exempt if total CFC income is no more than EUR 2 million, or if the CFC's effective tax rate is at least 13% and passive income is no more than 50%. The report is still due.
You should also take into account when the notification duty arises if you acquired the company before becoming resident, and the additional exemption conditions in TCU Art. 39-2.4 — this article does not cover them in detail.
Read more in the guide. Related: When you become resident, Leaving Ukraine.
