Publication date: 07.04.2025
Legal counsel since 2008, lawyer since 2012. Owner and co-owner of a BTI, a design organization, a construction company, an expedition company, and a transportation company. Deputy of local self-government bodies for two terms, member of the certification (lustration) commission of the National Police, member of the working group on drafting legislation.
Reporting on a Controlled Foreign Company (CFC) for 2024: Legal Support for Individuals
Controlled Foreign Companies (CFCs) are a significant element of international tax planning. However, after the implementation of new regulations in Ukraine, their use now requires strict reporting. Since 2022, individuals who qualify as controlling persons of foreign companies have been obligated to submit CFC reports to the tax authorities. In 2025, this reporting will cover the 2024 fiscal year.
This article is dedicated not only to analyzing legislative requirements but also to providing practical guidance on how to prepare a CFC report, what documents are needed, what services lawyers offer, and what the cost may be. If you are an owner or nominal beneficiary of a foreign company, this text will serve as a roadmap in a complex legal environment.
Key Benefits of Legal Support for CFC Reporting
- Time Efficiency. A lawyer takes care of analyzing the company’s structure, preparing reports, and filling out all necessary annexes. This allows the client to focus on their own affairs without unnecessary bureaucratic hassle.
- Legal Security. Professional support reduces the risk of errors in reporting, which could lead to fines, tax audits, or additional tax assessments.
- Personalized Approach. Legal assistance takes into account the individual characteristics of each company’s structure and its controlling person, ensuring accuracy and compliance with legal requirements.
What is a CFC and Who Is Required to Report?
A Controlled Foreign Company is a foreign legal entity that is controlled by an individual who is a resident of Ukraine. If a person owns a share in such a company or exercises actual control over it, they are considered a controlling person and must report the CFC.
The report must be submitted annually by May 1 for the previous reporting year. In 2025, this deadline applies to the 2024 fiscal year.
Stages of CFC Reporting
Legal consultation
Determining the company’s status, its activity, and collecting the necessary data.
Preparation of reporting documents
Completing the declaration of assets and income, the CFC annex, and the report itself.
Submission via the taxpayer’s electronic cabinet
Filing is done using a digital signature through the official Tax Service portal.
Question
Can a CFC report be submitted if the company’s financial statements are not ready?
Answer
Yes, in such cases a short-form report may be submitted. However, a complete report with financial documentation must still be submitted by December 31, 2025.
Question
Can I submit the report on my own without a lawyer?
Answer
Technically, yes. However, in practice, this carries a high risk of mistakes that could result in fines or tax inspections. Legal support ensures proper documentation and reduces legal and tax risks.
Submitting reports for Controlled Foreign Companies is not only a legal obligation but also a responsibility to the state. Errors in reporting may result in tax sanctions, while timely submission demonstrates business transparency and compliance with the law.
The legal team of attorney Oleksandr Serpeninov offers comprehensive support in preparing CFC reports, including report translation, consultations, submission assistance, and preparation of accompanying documents. This allows foreign company owners to focus on growing their business without being distracted by complex bureaucracy.
