Reminder: The Deadline for Filing CbC Reports for 2025 in Ukraine Is 31 December 2026

The Country-by-Country (CbC) report is one of the three tiers of transfer pricing documentation introduced in Ukraine in line with the OECD BEPS standards. It provides tax authorities with information on the allocation of a multinational enterprise (MNE) group’s revenue, profit, income tax accrued and paid, number of employees, and tangible assets across the jurisdictions in which the group operates.

For MNE groups whose financial year corresponds to the calendar year, the CbC report for 2025 must be filed in Ukraine, where the relevant statutory conditions are met, no later than 31 December 2026, i.e. within 12 months after the end of the relevant financial year.

Ukrainian entities that are part of MNE groups whose Ultimate Parent Entities (UPEs) are located in jurisdictions where the automatic exchange of CbC reports with Ukraine is not yet effective should pay particular attention to their reporting obligations. These jurisdictions include the USA, Canada, Vietnam, Israel, Kazakhstan, Nigeria, Botswana, Cabo Verde, Gabon, Greenland, Haiti, Mauritania, and Morocco.

A QCAA (Qualifying Competent Authority Agreement) is an agreement between the competent authorities of Ukraine and the relevant foreign jurisdiction that provides for the automatic exchange of CbC reports. The absence of an effective exchange mechanism may be one of the circumstances giving rise to a CbC filing obligation in Ukraine.

When Is a CbC Report Required to Be Filed in Ukraine?

The obligation to file a CbC report is determined based on the MNE group’s total consolidated revenue and the circumstances provided for by the Tax Code of Ukraine. The general revenue threshold is an amount equivalent to EUR 750 million or more.

Where the applicable threshold is met, a CbC report must be filed, in particular, if the Ukrainian taxpayer is the Ultimate Parent Entity (UPE) of the MNE group or has been authorised by the parent entity to file the report in Ukraine. A filing obligation may also arise where the UPE’s jurisdiction does not require CbC reporting, where an international agreement on the exchange of tax information is in effect between Ukraine and the relevant foreign jurisdiction but the applicable QCAA has not yet entered into force, or where there has been a systemic failure to exchange CbC reports under an otherwise effective agreement.

Ukrainian entities that are part of international groups should therefore assess their CbC reporting obligations in advance by confirming the current status of automatic exchange with the relevant jurisdiction, identifying the group entity responsible for filing, and aligning the data required for the report across the entire MNE group.

EBS’s transfer pricing team can help determine whether a CbC filing obligation arises in Ukraine and assist with the preparation and filing of the report in accordance with applicable statutory requirements.