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Submission of Controlled foreign company (CFC) reporting

At the Avitar consultation, you will be able to get answers to all questions about controlled foreign company (CFC) in Ukraine

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Submission of CFC Reports

  • If you registered or acquired a foreign company after 01.01.2022, which qualifies as a CFC in Ukraine, you must urgently submit a CFC notification to Ukrainian tax authorities.
  • If the company was registered/acquired before 01.01.2022, the notification is not required, except in the case of a change in the controller's status after this date.
  • All CFC controllers must submit a CFC report annually, regardless of the company's performance.
  • If your company does not qualify for CFC tax exemption, you will need to pay taxes on it, which will be calculated in the report and specified in the assets and income declaration.
  • If you have a foreign company and are unsure about your CFC obligations, we recommend contacting us for legal consultation.

What You Will Get During the Consultation

During an Avitar consultation, you will receive answers to the following questions:

  • Do you meet the criteria for being a CFC controller?
  • What to do if you are a dual resident in relation to CFC in Ukraine?
  • Do you need to submit a CFC notification?
  • When and how should you submit the CFC report?
  • How much tax do you need to pay for your CFC in Ukraine?
  • Can you use the CFC tax exemption?
  • How to structure your business considering CFC rules to reduce the tax burden?
  • How to reduce the risks of penalties for CFC?
Avitar helps with:

Avitar helps with:

  • Analyzing whether the CFC rules apply to you;
  • Determining whether there are grounds for exempting CFC profits from taxation in Ukraine;
  • Developing a business model to help reduce the tax burden;
  • Analyzing the CFC financial statements and determining the adjusted CFC profit subject to taxation in Ukraine;
  • Addressing CFC reporting;
  • Preparing the property and income tax declaration;
  • Preparing the CFC report and notification.
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What we do Avitar provides a full range of legal services to help correctly process

CFC reports and notifications, as well as optimize tax liabilities:

  • Consultations and analysis of CFC obligations: We help determine whether your company is a CFC, whether reporting is required, and whether you qualify for an exemption from taxation.
  • Preparation of reports: We assist in preparing the proper CFC report that complies with Ukrainian law, as well as all required notifications and declarations.
  • Tax calculation: If your company is not exempt, we help determine the taxes you need to pay for the CFC.
  • Tax structure modeling: We will develop the optimal structure for your business, taking into account CFC specifics to reduce the tax burden.
  • Minimizing the risk of penalties: We assist in avoiding penalties for reporting errors and late submission of documents.
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What we do Avitar provides a full range of legal services to help correctly process

How the service process works

1. Consultation and audit of your situation:

We begin by analyzing your foreign company, determining whether it falls under CFC rules and identifying any obligations.

2. Preparation of reports and notifications:

If your business is subject to CFC requirements, we will prepare the notifications and report to meet all tax legislation requirements.

3. Tax calculation:

If your company is not exempt, we will determine the amount of taxes you need to pay for the CFC.

4. Document submission:

We will file the reports and notifications with the tax authorities on time, ensuring the correctness of all submitted documents.

5. Tax burden optimization:

We also help structure your business in a way that minimizes tax liabilities using legal means to reduce taxes.

6. Monitoring and support:

We provide ongoing support to maintain compliance and minimize risks in your future activities.

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Penalties for CFC reporting violations:

  • Failure to submit reports: a fine of 100 living wages for working-age persons (as of 01.01.2023 — 268,400 UAH).
  • Late submission: a fine of 1 living wage (2,684 UAH) per day of delay, up to 50 living wages (134,200 UAH).
  • Failure to disclose CFC information: a fine of up to 1,000 living wages (2,684,000 UAH).
  • Late submission of documents after the deadline: a fine of 5 living wages (13,420 UAH) per day of delay, up to 300 living wages (805,200 UAH).

Why choose us?

Expertise in CFC:

We have a deep understanding of all aspects of CFC legislation, allowing us to effectively handle even the most complex issues.

Personalized approach:

Each client receives tailored consultation and solutions that fit their specific needs and situation.

Accuracy and timeliness:

We guarantee that all documentation will be submitted on time, in compliance with tax legislation.

Tax expense optimization:

Our lawyers and tax consultants help reduce the tax burden without violating the law.

Reducing penalty risks:

With our help, you can avoid mistakes in reporting and penalties.

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Case study:

One of our clients, a large international holding company that owns several foreign companies, failed to submit CFC reports on time. It turned out that after 01.01.2022, the company had a changed controller status, requiring the submission of a CFC notification. We helped them prepare the necessary documentation and submit it on time, avoiding significant fines. Furthermore, we analyzed their tax structure and suggested changes that reduced their tax burden by several million UAH. If you have any questions about CFCs or need help with reporting, contact Avitar. We will provide qualified support and help you avoid penalties, optimize your tax burden, and ensure compliance with the law.

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Case study:
unescozakaz.uaЛоготип АZPromo RepublicBookimedIdea.meclarioPaycoreioRadioactivefilmMackeeperЛоготип MorzaPine

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