Country-by-Country Report (CbCR): the filing deadline is approaching

In this article, we will review in detail the current requirements for filing a Country-by-Country Report (CbCR) and analyse key nuances for multinational groups whose parent companies are registered in the United States, Canada and other jurisdictions that do not yet have automatic CbCR exchange with Ukraine.

Why is this important? Despite the rule’s perceived simplicity, in some situations it may not be clear to Ukrainian companies whether they are required to file a CbCR themselves. However, the liability for non-submission or late submission is significant — and can create both financial and reputational risks for the entire group. This is why it is critically important for companies to correctly and timely assess their status within the CbC reporting framework and understand the nuances that may affect whether CbCR filing is required in Ukraine.

Why now? Because the filing deadline for the CbCR for 2024 is approaching, until the end of the current year. This means that now is the best time to verify whether a Ukrainian company has an obligation to file the report, and, if necessary, prepare it. Delaying the assessment may result in insufficient time to gather information, obtain internal approvals and prepare the report technically.

1. Who is required to file

Ukrainian companies that are part of a multinational group of companies (MNE Group) must file a CbCR if certain conditions are met.

Interestingly, filing of CbCR does not depend on whether the company conducted controlled transactions subject to transfer pricing. In other words, even if there were no such transactions, the report is still mandatory. The Tax Code of Ukraine (TCU) does not impose filing l requirements on companies without controlled transactions,  underscoring the universality of this tool. Moreover, the State Tax Service (STS) draws attention to this in its clarifications (ind. tax consultation dated 20.08.2025 № 4470/ІПК/99-00-21-02-03).

CbCR is filed only when two key conditions exist: first, legal grounds for filing are present; and second, the MNE Group meets the consolidated revenue threshold.

2. Grounds for filing

Legislation provides an exhaustive list of grounds for filing a CbCR. The existence of at least one triggers the filing obligation:

• The Ukrainian company is the parent entity of the MNE Group. This applies starting from the 2023 financial year. If the Ukrainian company heads the group, reporting has already been mandatory and familiar to taxpayers.
• The parent company authorises a Ukrainian subsidiary. If the parent company is located abroad, it may authorise a Ukrainian resident to file a CbCR on behalf of the MNE group. As noted by the STS, the TCU does not set formal requirements for such authorisation, so it should reasonably be executed through an internal corporate document — such as board minutes, an order, or a letter.
• No CbCR filing obligation exists in the parent company’s jurisdiction. If the legislation of the parent company’s country does not require CbCR filing, the Ukrainian entity must file the CbCR in accordance with Ukrainian rules.
• No effective QCAA exists. Even if a double tax treaty or another information-exchange treaty exists between Ukraine and the jurisdiction of the parent entity, a CbCR must be filed if a Qualifying Competent Authority Agreement (QCAA) enabling automatic CbCR exchange is not in effect as of the end of the financial year for which the report must be submitted.
• Systemic QCAA non-compliance. The report must be filed if systemic non-compliance with QCAA obligations is established on the parent jurisdiction’s side. The STS notifies the Ukrainian entity within 10 business days of identifying such a fact.

A crucial element is the timeline for when grounds 2–5 apply. According to the TCU, their application depends on when the Multilateral CbC Agreement becomes effective with at least one jurisdiction that is a partner of Ukraine for automatic information exchange. Though the legislative wording is complex, in practice, this means these grounds apply from the period in which the Multilateral CbC Agreement — as a type of QCAA — became effective for Ukraine. Formally, this occurred on 4 July 2024.

Therefore, grounds 2–5 apply for the first time to the 2024 reporting period, and CbCR must be filed in 2025.

A key point requiring particular attention now is the effectiveness of the Multilateral CbC Agreement between Ukraine and other jurisdictions. As of today, it is in force in 88 jurisdictions, from which Ukraine can receive information — including classic low-tax jurisdictions such as Belize, the Cayman Islands, Guernsey, and Cyprus. Ukrainian companies whose parents are registered in these jurisdictions do not need to file CbCR — provided that the parent files CbCR locally and no other grounds apply.

Meanwhile, the Multilateral CbC Agreement is not in effect for Ukraine with several commonly used jurisdictions (e.g., Canada), and not signed at all with others (in particular, the United States).

For these jurisdictions, where no QCAA (Multilateral CbC or Bilateral BCAA CbC) is active and the group’s parent is registered, CbCR rules apply from the 2024 financial year. This is irrespective of whether a double tax treaty exists with Ukraine. Accordingly, a Ukrainian resident must file CbCR for 2024 in 2025.

The current status of the Multilateral CbC Agreement can be verified on the OECD website.

3. Consolidated revenue threshold

For an MNE Group to be required to file CbCR, its total consolidated revenue for the financial year preceding the reporting year must meet the established threshold. Currently, this threshold is equivalent to €750 million for all grounds listed above.

In some cases, the consolidated revenue threshold may be determined based on the parent company’s jurisdiction. For example, for the US — where no active QCAA with Ukraine exists — one should rely on the threshold set by US legislation when assessing CbCR filing requirements in Ukraine. This approach may also apply when reporting is triggered by the authorisation of a Ukrainian subsidiary, the absence of a CbCR filing obligation in the parent jurisdiction, or  the non-applicability of QCAA.

In other words, if the MNE Group’s consolidated revenue for the year preceding the reporting period equals or exceeds €750 million, the Ukrainian entity must file a CbCR when one of the above grounds applies.

For this purpose, consolidated revenue should be calculated at the average official UAH-EUR exchange rate for the calendar year preceding the reporting year.

4. What if the MNE Group has several Ukrainian entities?

 Suppose more than one group entity is a taxpayer in Ukraine and certain grounds exist for CbCR filing (absence of CbCR obligation in the parent jurisdiction, inactive/non-effective QCAA) In that case, the group may appoint one of these entities as the authorised CbCR filer in Ukraine.

The authorised entity must notify the STS by filing a notification of participation in the MNE Group.

Importantly, the general deadline for filing the participation notification (by 1 October) does not necessarily apply here. Therefore, meeting this deadline is not mandatory for authorising an entity unless controlled transactions took place during the reporting year.

If no authorisation is made, each Ukrainian entity must file CbCR separately to avoid penalties. Currently, legislation does not provide any alternative  means to fulfil this obligation.

5. CbCR filing deadline

The report must be submitted within 12 months following the end of the financial year.

CbCR is prepared for the parent company’s financial year, which may differ from the calendar year.

In practice, this means:

• If the MNE Group’s financial year ended, for example, on 30 September 2024, the CbCR for 2024 should already have been filed.
• If the financial year ends on 31 December 2024, the taxpayer has almost one month to finalise and submit the CbCR in 2025.

Thus, the deadline depends on the parent company’s financial year and must always be taken into account when planning the reporting process.

6. How to file CbCR

The Country-by-Country Report may only be submitted electronically, in the standardised format specified by Ukrainian law.

This means one cannot simply submit the same version of the report filed by the parent company abroad. For Ukraine, the official CbCR form established in the TCU and related regulations must be used.

7. Exemption from filing CbCR

A Ukrainian taxpayer may sometimes be exempt from filing CbCR even where the parent jurisdiction has no CbCR filing obligation or where QCAA is inactive/non-effective.

To qualify, all of the following conditions must be satisfied:

• Another group entity filed CbCR in its jurisdiction.The CbCR for the relevant year must be filed by another authorised group entity in its tax jurisdiction. The parent company must formalise its decision to appoint this entity in an internal corporate document — resolution, order or letter.
  Important: If the report is filed only to meet local domestic requirements and not for exchange purposes, the entity is not considered authorised.
• Deadline met. The authorised entity filed the report no later than the deadline set by the Tax Code.
• Automatic exchange applies. The legislation of that jurisdiction must allow the report to be filed for automatic exchange purposes.
• QCAA is effective and complies with. A valid QCAA must exist between Ukraine and the authorised entity’s jurisdiction as of the end of the reporting financial year, and the jurisdiction did not notify Ukraine of systemic non-compliance.
• Notification of authority:

• Non-resident: the authorised entity notified its tax authority about its right to submit CbCR;
• Ukrainian resident: the Ukrainian taxpayer notified the STS of the authorised entity through the standard notification on participation in the MNE Group.

Only if all the conditions above are met may a Ukrainian entity be exempt. However, no exemption applies where the Ukrainian company is the parent entity or the parent explicitly authorises the Ukrainian subsidiary to file.

8. Liability for non-compliance

Failure to submit, late submission or submission of inaccurate information in CbCR entails financial penalties:

(i) Failure to file

• Penalty equals 1,000 minimum living wages (UAH 3,028,000 or approx. USD 71,650 in 2025).
• Paying the penalty does not exempt from the reporting obligation.
• If the report is not filed within 30 days after the penalty is paid, an additional penalty applies — 5 living wages per day of delay (UAH 15,140 or approx. USD 360 in 2025, capped at UAH 908,400 or approx. USD 21,500).

(ii) Late submission

• Penalty — 1 living wage per day of delay (UAH 3,028 or approx. USD 72 in 2025, capped at UAH 3,028,000 or approx. USD 71,650).

(iii) Inaccurate information / errors in CbCR

• Penalty equals 200 living wages (UAH 605,600 or approx. USD 14,330 in 2025).
• Paying the penalty does not exempt from filing a corrected report.
• If the corrected report is not submitted within 30 days after notification, it is treated as late, and the same penalty applies.
  • Exceptions: the penalty does not apply if errors do not affect: identification of the MNE Group participant’s residence jurisdiction; identification of MNE Group participants; determination of the filing jurisdiction.
• In such cases, the taxpayer must correct the errors independently or within 30 calendar days after the tax authority’s notice.

Thus, liability for violations  of CbCR requirements may be significant, and adherence to deadlines and data accuracy is critically important.