Owners and controlling persons of controlled foreign corporations (legal entities or otherwise; such as trusts, foundations, etc.) must report on such international structures and their profits, paying taxes related to such profits in Ukraine.

Our services

  • CFC diagnostics, specifically:
    • identifying controlling parties
    • establishing reporting obligations for CFCs
    • calculating projected tax payable by the controlling person related to all operating CFCs
    • providing recommendations for improving organisational structures and business model.
  • Analysis of potential risks and threats arising within the framework of taxation rules for CFCs, developing draft ownership structures and business models while taking into account the tax rules for controlled foreign companies in Ukraine and providing recommendations.
  • Assessment of the feasibility for liquidating CFCs, evaluating the tax implications for the controlling person (depending on the timing of liquidation and any assets owned by the CFC).
  • Providing support on issues related to reporting on CFC, specifically:
    • analysing CFC financial statements and determining adjusted profit before tax in Ukraine
    • reviewing CFC reports before their submission to the Ukrainian tax authorities
    • analysing the possible tax surcharge risks and providing recommendations
    • assisting in the preparation of personal income tax returns, support during tax audits, and preparing responses to Ukrainian tax authority inquiries 

How KPMG in Ukraine can help