Ukrainian companies must independently submit CbC report for 2024 if their "parent" companies are in the USA, Canada or Israel

If Ukrainian company is a part of the international group and the main company (parent) is registered in the USA, Canada or Israel, it will have to submit CbC report for 2024 independently. Reason is that the automatic exchange of reports with these countries has not yet fully worked as of the end of 2024.

As a part of the international cooperation in the tax control and transfer pricing spheres, Ukraine participates in the automatic exchange of the country-by-country reports (CbC – Country-by-Country Reporting). It officially entered into force on July 4, 2024.

Ukrainian companies that are part of the international group of companies must submit the CbC report in cases when:

- parent company is registered in a country with which international tax information exchange agreement has been signed,

- relevant automatic exchange agreement (QCAA) has not yet entered into force as of December 31, 2024.

As of the end of 2024, such agreement was not yet in force with the USA, Canada and Israel. 

For reference:

Regarding entry into force of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports: https://tax.gov.ua/media-tsentr/novini/825385.html.

Signatories of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports are published on the OECD website (https://www.oecd.org/tax/automatic-exchange/about-automatic-exchange/cbc-mcaa-signatories.pdf) and list of countries for which it entered into force (https://web-archive.oecd.org/temp/2024-04-30/437036-country-by-country-exchange-relationships.htm)