The Transfer Pricing Department of the Main Department of the State Tax Service in the Vinnytsia region has summarized the most common mistakes made by taxpayers when completing the Notification of Participation in a Multinational Enterprise Group (MNE Group) for 2024.
The conclusions are based on the annual monitoring of Notifications submitted to the State Tax Service of Ukraine. The relevant information was published on 29 November 2024.
Top 10 Common Mistakes
Based on the analysis, the most frequent mistakes include, in particular:
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Incorrect completion of the address of the parent company or an MNE group member (fields 21.1–21.13 and 30.1–30.13). Fields 21.5–21.6 and 30.5–30.6 (city) are mandatory.
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Use of Cyrillic characters in fields that must be completed in English (fields 7.2, 14.2, 21.4, 21.6, 21.8, 21.10, 22.2, 24.2, 30.4, 30.6, 30.8, 30.10, 31.2).
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Failure to indicate the jurisdiction code of the parent company (field 20).
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Incorrect determination of the reporting period (field 1.1).
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Absence of the MNE group’s financial year-end date (field 8).
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Failure to indicate the legal address type code of the parent company (field 19, codes OECD301–OECD305).
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Failure to indicate the name of the multinational enterprise group (field 7.1).
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Absence of a mark regarding the preparation of consolidated financial statements (field 9, codes UNC201 or UNC202).
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Incorrect indication of the parent company’s TIN and the jurisdiction code (fields 17.1–17.2).
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Failure to indicate the jurisdiction code of an MNE group member (field 29) where Country-by-Country Reporting is required and the group’s revenue equals or exceeds EUR 750 million.
Recommendations
The State Tax Service has developed an infographic featuring examples of common mistakes and practical recommendations on how to avoid them. The materials are available at the following link:
“Avoiding the Top 10 Mistakes When Completing the Notification of Participation in a Multinational Enterprise Group.”
The State Tax Service has prepared an infographic with examples of common mistakes and practical guidance on how to avoid them. Timely review and voluntary correction of errors helps taxpayers avoid penalties.
Liability
Pursuant to Article 120 of the Tax Code of Ukraine, liability is imposed for failure to submit, late submission, or submission of inaccurate information in the Notification of Participation in an MNE Group.
Under Article 120.5 of the Tax Code of Ukraine, the penalty for providing inaccurate information amounts to 50 subsistence minimums (for 2023 — UAH 134,200).
No penalty applies if the errors did not affect the identification of MNE group members or jurisdictions and were corrected by filing an amended Notification within the statutory deadline.
