Country-by-Country Report: which companies are required to submit it in Ukraine this year?

For several years now, Ukrainian legislation has required the submission  of the Country-by-Country Report (the “Report”). Previously, it was submitted only by groups whose parent companies are registered in Ukraine. Now this requirement is expanding, and this year a wider range of companies must submit the Report for 2024.

What changes have taken place in Ukrainian legislation?

In July 2024, the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports entered into force for Ukraine. This means that 2024 was the first reporting period for  the submission of the Report, and already this year, subsidiaries of international groups with consolidated revenues of more than EUR 750 million must submit this Report in Ukraine under certain conditions.

Which companies must submit the Report for 2024:

• parent companies that are registered in Ukraine (this was also the case until 2024);
• companies authorized by the Group to submit such a Report
  in Ukraine (this was also the case before 2024);
• subsidiaries of the groups with revenues of more than EUR 750 million. 
• The key condition is if the agreement on automatic exchange of reports has not entered into force between Ukraine and the country where the Group submitted the Report.

Such countries include the USA, Canada, Sweden. Accordingly, if the Report is submitted in one of these countries, the Ukrainian company must submit the Report in Ukraine (the so-called “secondary filing”).

85 countries exchange reports with Ukraine, including Germany, Poland, Switzerland, Cyprus, etc. That is, there is no need to carry out “secondary filing”.

When to submit a Report?

The report is submitted no later than 12 months after the last day of the financial year, which begins from January 1 to December 31, 2024.

Examples:

1. if the fiscal year ended on December 31, 2024, then the filing deadline is December 31, 2025;
2. if the fiscal year ended on August 31, 2025, then the filing deadline is August 31, 2026.

How to submit a Report in Ukraine?

To date, the form of the Report has been approved by the Order of the Ministry of Finance of Ukraine dated December 14, 2020 No. 764, according to which the XML schema has been developed and published:

• The published XML schema provides for the preparation of separate XML files for each jurisdiction and each member company of the MNE group.
• By example, this means that for an MNE group that includes 200 companies in 40 jurisdictions, the relevant taxpayer in Ukraine will have to prepare and submit 241 XML files.
• The approved form of the Report provides for the need to translate
  some fields of the Report into Ukrainian, etc.

Taking into account all the difficulties of preparing the Report, we recommend that you prepare for the first submission in advance.