Report and notice on a controlled foreign company (CFC)

Key Terms and Definitions:

Controlled Foreign Company (CFC):

A company registered abroad that is controlled by a physical or legal person residing in Ukraine. If you control such a company, you need to submit a notification about this to the tax service.

CFC Controller:

A person who has significant or decisive influence over the activities of the CFC. This may be the owner of more than 50% of the shares or a person exercising actual control.

Electronic Taxpayer Cabinet:

An online system through which notifications and reports are submitted to the Ukrainian tax authorities.

Changes in Control:

Changes related to the rights of the controller, such as the purchase/sale of shares, acquisition, or loss of control over the company.

How Exactly We Assist?

Avitar provides full legal support in preparing and submitting the CFC notification:

Analysis of Your Situation: We will help determine if your company falls under the CFC rules and evaluate the necessity of submitting a notification in your case.
Preparation and Submission of the Notification: Our lawyers will prepare the CFC notification, taking into account all nuances of your situation, and submit it through the electronic taxpayer cabinet.
Consultations on Changes in Control: If there are any changes in your company, we will help you properly declare these changes and ensure compliance with tax legislation requirements.
Tax Liability Optimization: We will analyze if the CFC's profit can be exempt from taxation in Ukraine and develop a strategy to reduce the tax burden.
Reporting and Tax Declarations: We assist in preparing the tax declaration on property status and income, as well as CFC reporting.

Which Companies Should Be Reported to the Tax Authorities?

You need to report companies/shares in companies created/acquired after January 1, 2022. Additionally, within 60 days, you must report if a company created/acquired before January 1, 2022 has undergone changes (purchase/sale of shares or acquisition/loss of control) related to the controller.

Who Submits the Notification?

The notification is submitted separately by each controller through the Electronic Taxpayer Cabinet.

If You Have Questions, Avitar Will Help:

Analyze whether CFC rules apply to you.
Determine if there are grounds for exempting the CFC’s profits from taxation in Ukraine.
Develop a business model that helps reduce the tax burden.
Analyze the financial statements of the CFC and determine the adjusted profit subject to taxation in Ukraine.
Clarify the CFC reporting process.
Prepare the property and income tax declaration.
Prepare the report and notification about the CFC.

Why Choose Us?

Expertise in Tax Law:

We have a deep understanding of Ukrainian tax legislation, particularly in the field of CFCs, and are capable of effectively addressing complex legal issues.

Individual Approach:

Every business is unique, so we approach each client individually, taking into account all specifics of your operations and company structure.

Comprehensive Support:

We not only help prepare the CFC notification but also provide comprehensive legal support, including preparing reports and declarations.

Efficiency:

We guarantee the prompt and timely submission of notifications and other reports to the tax authorities.

Experience in International Matters:

Our lawyers have extensive experience working with international companies, allowing us to effectively consult on all aspects of controlling foreign companies.

Case Studies

Case: Ukrainian Company That Changed Control Structure

Problem: A Ukrainian company acquired 60% of shares in a foreign company. After this, it became necessary to submit a notification about the changes in the control structure according to CFC rules.
Solution: We conducted a detailed analysis and prepared the notification about the changes in control over the foreign company, submitted it through the Electronic Taxpayer Cabinet, and ensured compliance with tax requirements.
Result: The client successfully submitted the notification on time, avoiding penalties and maintaining legal security.

Contact Us for professional help in preparing CFC notifications and resolving tax issues related to controlling foreign companies!

What Clients Say About our Work

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Дмитро Будорін, CEO та Co-founder Hacken

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Before meeting the guys, their recommendations. In my view, the development and scaling of the business was, it was necessary to rush, and then we will deal with putting in order the processes and documents

Eugene Kuzmin, CEO MORZA.co

Notification of Controlled foreign company (CFC)

What is the Notification about a Controlled Foreign Company (CFC)?