On July 2024, the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (hereinafter – MCAA CbC) came into force.

Deputy Minister of Finance Svitlana Vorobei noted that 2024 would be the first reporting period for Ukraine in order to exchanging reports.

The purpose of joining the MCAA CbC for Ukraine is to join the international system of automatic exchange of Country-by-Country Reports, which unites more than 100 countries of the world.

Implementation of International Automatic Exchange of Country-by-Country Reports is an element of the BEPS Action 13, which is a part of the BEPS minimum standards that Ukraine has committed to implement.

Country-by-Country Reporting System will allow the tax authorities of Ukraine to receive comprehensive information on the activities of international groups of companies across jurisdictions, as well as to conduct an effective analysis of scope, structure of transactions and the specifics of the activities of international groups of companies for the purposes of Transfer Pricing control.

The Country-by-Country Reporting is an element of a three-tiered standardised approach to transfer pricing documentation for international groups of companies, which also consists of a transfer pricing documentation (local file) and a global transfer pricing documentation (master file).

For reference

The Country-by-Country Report must be submitted by taxpayer if the international group of companies has a total consolidated group revenue of more than EUR 750 million during the fiscal year preceding the reporting fiscal year, which is calculated according to the accounting standards applied by the parent company of the international group of companies (in case of the absence of information – according to the international accounting standards), along with at least one of the circumstances specified in sub-clause 39.4.10 of clause 39.4 of Article 39 of the Tax Code of Ukraine.

The form of the Country-by-Country Report of the international group of companies and the procedure for its filing are approved by the Order of the Ministry of Finance of Ukraine.

Source: https://mof.gov.ua