In 2026, controlling persons of controlled foreign companies (CFCs) must submit reports for the 2025 reporting year within the deadlines established by law. This was reminded by the State Tax Service of Ukraine (STS).
The obligation to report on CFCs is stipulated by Article 39² of the Tax Code of Ukraine and applies to Ukrainian legal entities and individuals who are recognized as controlling persons of foreign companies.
When to submit CFC reporting in 2026
Tax legislation establishes different reporting deadlines depending on the status of the controlling person.
Deadline for legal entities
The report on controlled foreign companies for 2025 must be submitted by March 2, 2026, together with the corporate income tax return.
Deadline for individuals
The CFC report for 2025 must be submitted by May 1, 2026, simultaneously with the annual declaration of assets, income, and expenses.
Short-form and full CFC report: what you need to know
If a controlling person submitted a short-form CFC report due to the inability to prepare the financial statements of the foreign company on time, a full report must be submitted by December 31, 2026 (based on the results of 2025).
Notification of changes or termination of control over a CFC
Controlling persons are also required to notify the tax authority of changes related to controlled foreign companies. In particular, the acquisition of a share, change in ownership share, or termination of control must be reported to the STS within 60 calendar days from the date the relevant event occurs.
CFC financial statements: documents to be attached
Certified copies of the financial statements of the controlled foreign company must be attached to the CFC report.
The reporting must be submitted separately for each controlled foreign company.
Support with CFC reporting
If you need assistance with preparing CFC reports, analyzing ownership structures, or assessing tax risks, the specialists of Kreston Ukraine are ready to provide professional advisory support.
