Automatic exchange of reports by country of international groups of companies (Country-by-Country Reporting, CbC) is already in effect between Ukraine and 99 countries around the world. However, automatic exchange of the CbC reports has not yet entered into force between Ukraine and a number of states and territories.
These are Canada, Socialist Republic of Vietnam, Israel, Republic of Kazakhstan, Federal Republic of Nigeria, Republic of Botswana, Republic of Cape Verde, Republic of Gabon, Greenland, Republic of Haiti, Islamic Republic of Mauritania and Kingdom of Morocco.
Also, the bilateral agreement on the automatic exchange of the CbC reports between Ukraine and the United States of America has not yet been signed.
To launch the automatic exchange of reports between specific countries, all necessary legal and technical procedures must be completed on both sides. If these conditions are not met, the automatic exchange mechanism is temporarily not applied according to provisions of the Multilateral CbC Agreement.
Country-by-country report of the international group of companies is one of the components of tax control over transfer pricing. It contains information on the distribution of income, profits, taxes and economic activities of the international groups of companies between different jurisdictions.
Ukraine signed the Multilateral Competent Authority Agreement on the Exchange of the Country-by-Country Reports on November 3, 2022 and it officially entered into force on July 4, 2024.
Full list of countries with which the automatic exchange is already in effect and not yet in effect can be found under the "notice - reminder" link: https://tax.gov.ua/en/new-about-taxes--news-/1011626.html
It is recommend to take into account current status of the international information exchange for planning activities, preparing reports and controlling transfer pricing.