CFC notification: timely compliance with Ukrainian requirements without unnecessary risks
- 15+ jurisdictions
- from 5 business days
- free 30-minute consultation
- 15+ jurisdictions
- from 5 business days
- free 30-minute consultation
We help prepare and file a controlled foreign company (CFC) notification in accordance with Ukrainian law. We work with companies in Estonia, Poland, the United Kingdom, Cyprus, Georgia, Latvia, Romania and other jurisdictions.
You focus on growing your business while we analyse the ownership structure, verify the grounds for filing the notification, prepare the documents and explain Ukrainian legal requirements. We help fulfil your obligations to the tax authorities without unnecessary risks or errors.
We help prepare and file a controlled foreign company (CFC) notification in accordance with Ukrainian law. We work with companies in Estonia, Poland, the United Kingdom, Cyprus, Georgia, Latvia, Romania and other jurisdictions.
You focus on growing your business while we analyse the ownership structure, verify the grounds for filing the notification, prepare the documents and explain Ukrainian legal requirements. We help fulfil your obligations to the tax authorities without unnecessary risks or errors.
Who the service is for CFC notification
A notification of the acquisition or disposal of an interest in a controlled foreign company may be mandatory for Ukrainian resident individuals and legal entities that meet the control criteria established by Ukrainian law.
This obligation most often arises for owners of foreign businesses, founders or beneficial owners of companies abroad, entrepreneurs opening businesses in EU countries or other jurisdictions, and Ukrainian residents expanding their international business structure.
- This service is for you if:
You are a Ukrainian tax resident and have formed or acquired a company abroad.
You acquired, disposed of or changed an interest in a foreign company, which may trigger an obligation to file a CFC notification.
You control a foreign company or may meet the control criteria established by Ukrainian law.
You plan to form a company in the EU, the United Kingdom or another jurisdiction and want to assess your CFC obligations in advance.
You have companies in several countries and want to determine correctly when and for which company a notification must be filed.
You work in IT, e-commerce, consulting or digital services through a foreign company and want to comply with Ukrainian legal requirements.
- This service is not for you if:
You are not a Ukrainian tax resident and have no CFC obligations in Ukraine.
You do not have a foreign company and do not plan to open one in the near future.
You are not a controlling person of a foreign company and do not meet the CFC criteria established by Ukrainian law.
You only need foreign company formation without an analysis of CFC obligations and filing a notification.
What is a CFC notification and why is it required?
CFC notification
Controlled foreign company (CFC)
What is included in support for CFC notification
- We analyse the ownership structure and determine whether you must file a CFC notification under Ukrainian law.
- We verify the grounds for filing, the deadlines and the amount of information required in your situation.
- We prepare a list of required documents, check whether they are complete and provide recommendations on their preparation.
- We prepare the CFC notification and verify the details, information about the controlling person, foreign company data and other information before filing.
- We explain your ongoing CFC obligations, reporting deadlines and the documents that should be retained to comply with legal requirements.
- We help prepare responses and explanations if the tax authority sends additional requests after the notification is filed.
4 steps from the first enquiry to filing a CFC notification
We analyse your situation
During the consultation, we determine whether you must file a CFC notification and analyse the ownership structure, company jurisdiction and circumstances affecting compliance with Ukrainian law. After the consultation, you clearly understand your next steps.
We review the documents
We prepare a list of documents required in your situation, check whether they are complete and identify any missing information. This allows the notification to be prepared on time without unnecessary delays.
We prepare the notification
Once the documents are approved, we prepare the CFC notification and verify the details, information about the controlling person and other important data to minimise the risk of technical or formal errors.
We provide support after filing
If the tax authority sends additional requests after filing, we help prepare responses and explanations. Where necessary, we also advise on ongoing CFC obligations and future reporting.
How much does support cost CFC notification
- Quick response
- No obligation
- Confidential
- Quick response
- No obligation
- Confidential
The fee may include an analysis of your situation, verification of the grounds for filing and the documents, preparation of the CFC notification, advice on ongoing obligations and support in communications with the tax authorities.
An analysis of the international business structure, preparation of CFC reports, obtaining documents from foreign public registers, document translation, tax residency support, foreign company formation and other legal services required in your situation may be agreed separately.
After a brief consultation, the KRYNO team will calculate the cost for your specific situation.
Everything you need to file a CFC notification
Myths and facts about CFC notifications
Common assumptions:
“If the company has no activity, no CFC notification needs to be filed.”
“A CFC notification and CFC reporting are the same document.”
“If a company is registered in an EU country, the CFC rules do not apply.”
“Only an owner holding 100% of the company must file a notification.”
The reality:
The obligation to file depends on the occurrence of circumstances specified by the Tax Code of Ukraine, rather than whether the company has activities or income.
These are different obligations. A notification is filed in the circumstances provided by law, while a CFC report is filed for the relevant reporting period.
The company's jurisdiction of registration does not exempt its controlling person from Ukrainian legal requirements, if that person is a Ukrainian tax resident.
The CFC rules apply not only to owners holding 100% of a company, but also to persons who meet the control criteria established by the Tax Code of Ukraine.
“If the company has no activity, no CFC notification needs to be filed.”
The obligation to file depends on the occurrence of circumstances specified by the Tax Code of Ukraine, rather than whether the company has activities or income.
“A CFC notification and CFC reporting are the same document.”
These are different obligations. A notification is filed in the circumstances provided by law, while a CFC report is filed for the relevant reporting period.
“If a company is registered in an EU country, the CFC rules do not apply.”
The company's jurisdiction of registration does not exempt its controlling person from Ukrainian legal requirements, if that person is a Ukrainian tax resident.
“Only an owner holding 100% of the company must file a notification.”
The CFC rules apply not only to owners holding 100% of a company, but also to persons who meet the control criteria established by the Tax Code of Ukraine.
- FAQ
Frequently Asked Questions about CFC notifications
If the notification is not filed within the statutory period, the controlling person may be subject to a penalty under the Tax Code of Ukraine of up to 300 subsistence minimums for an able-bodied person. To avoid risks, we recommend checking your CFC obligations as soon as the grounds for filing arise.
It may be required. The obligation depends not on the existence of income or business activity, but on the circumstances specified by the Tax Code of Ukraine. Before filing, we recommend checking whether this obligation applies to you.
Preparing a CFC notification usually takes 1 to 3 business days if all required documents are ready. However, the timeframe may vary depending on the ownership structure, number of companies and document readiness. After the initial consultation, we will provide an estimated timeframe for your situation.
Yes, you can file the notification yourself. However, you should first determine correctly whether a filing obligation has arisen, which event must be reported, whether you are a controlling person, which data must be included in the form and which deadlines apply to your case.
Paying taxes abroad does not cancel Ukrainian CFC requirements. If you are a Ukrainian tax resident, you should separately check which obligations arise in your situation.
A CFC notification must be filed within 60 calendar days of acquiring or disposing of an interest in a foreign company, or of commencing or terminating actual control over it. It is important to determine the date from which this period begins correctly, so we recommend assessing your CFC obligations immediately after the relevant event.
Not always. What matters is not only the size of the interest, but also whether the control criteria established by the Tax Code of Ukraine are met. Each situation must therefore be analysed individually.
Yes. If a controlling person holds interests in or exercises actual control over several foreign companies, a separate notification is filed for each company for which the grounds for filing have arisen. During a consultation, we will help determine which notifications must be filed.
File your CFC notification on time and without unnecessary risks
Most errors arise not from ignorance of the law, but from the difficulty of determining CFC obligations, filing deadlines and document requirements. The earlier your situation is assessed, the easier it is to comply without unnecessary risks.
During a 30-minute consultation, we will analyse your ownership structure, determine whether a CFC notification must be filed, explain your ongoing obligations and calculate the cost of support for your situation.
