Country-by-Country Report of an international group of companies – when it should be submitted for the first time?

On 2 September 2024, the news was published on the website of the Ministry of Finance of Ukraine that the Multilateral Agreement of the Competent Authorities on the Automatic Exchange of Country-by-Country Reports entered into force for Ukraine in July 2024.

As a reminder, the Country-by-Country Report of an international group of companies contains information on the main financial indicators of the group by jurisdiction, as well as detailed information about each company of the group, including the number of employees, types of activities, identification numbers and addresses.

What changes with the entry of this agreement into force?

Until recently, only those international groups of companies whose parent companies are registered in Ukraine were required to submit a Country-by-Country Report starting from the 2022 reporting year. At present, the requirements for this Report will be applicable to all other international groups whose consolidated income for the year preceding the reporting year exceeded the equivalent of EUR 750 million.

In an ideal scenario, the jurisdiction in which the group submitted the Report automatically exchanges information with Ukraine, and therefore its separate submission in Ukraine (so-called ‘secondary submission’) is not required. At the same time, there may be cases where the group may be obliged to submit the Report in Ukraine as well, for example, in the event of systematic non-fulfillment by other countries of their obligations to exchange information with our state.

What is the first reporting year for CbC?

The Ministry of Finance of Ukraine has confirmed that the 2024 reporting year is the first reporting period for the exchange of Country-by-Country Reports. We do not rule out that the STS may publish additional clarifications and instructions in this regard. We will keep our finger on the pulse and promptly inform you about such publications.

If you have any questions regarding the legal requirements for submitting the Report or preparing it, we will be happy to help you.

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