The State Tax Service of Ukraine has announced that the automatic exchange of Country-by-Country (CbC) reports between Ukraine and 99 jurisdictions is already in force.
At the same time, automatic exchange of CbC reports with several countries has not yet entered into effect. For multinational enterprise groups, this issue is important for complying with transfer pricing documentation requirements, filing Country-by-Country reports, and assessing tax risks.
Countries where automatic exchange of CbC reports Is not yet effective
As of May 2026, automatic exchange of CbC reports between Ukraine and several jurisdictions has not yet been implemented. These include: Canada, Vietnam, Israel, Kazakhstan, Nigeria, Botswana, Cabo Verde, Gabon, Greenland, Haiti, Mauritania, and Morocco.
The State Tax Service separately notes that Ukraine and the United States have not yet signed a bilateral agreement on the automatic exchange of CbC reports. This is due to pending legal or technical procedures required to launch information exchange between the competent authorities of both countries.
Why it matters for businesses
A Country-by-Country Report (CbC Report) is one of the key elements of transfer pricing control for multinational enterprise groups.
Such reports include information regarding:
1) allocation of revenues and profits between jurisdictions; 2) taxes paid;
3) economic activities of group entities;
4) structure of the multinational group.
The absence of automatic exchange with certain jurisdictions may affect:
1) reporting procedures;
2) the volume of requests from tax authorities;
3) tax risk assessment; preparation of documentation for multinational groups;
What multinational groups should pay attention to
International companies are advised to regularly monitor the current status of automatic information exchange between jurisdictions where group entities operate.
This is especially important when:
- preparing a Notification of Participation in a Multinational Enterprise Group;
- preparing a Master File;
- preparing a CbC Report;
- analysing transfer pricing documentation obligations in Ukraine;
- planning internal tax compliance procedures.
Kreston Ukraine support
Kreston Ukraine specialists provide comprehensive support to multinational enterprise groups in transfer pricing and controlled foreign company reporting matters in accordance with Ukrainian legislation and OECD standards.
Services include:
- preparation of Notification of Participation in a Multinational Enterprise Group;
- preparation of a Master File;
- preparation of a Country-by-Country Report (CbC Report);
- transfer pricing risk assessment;
- support during communication with tax authorities;
- consultations
Source: State Tax Service of Ukraine.
