As a member of the global auditing network Crowe Global, Crowe Erfolg Ukraine actively contributes to the implementation of international standards in financial reporting and business process optimization. Today, we want to share important information based on data from the State Tax Service of Ukraine: Ukrainian parent companies have presented CbC Reports for the first time, marking a significant stride towards greater transparency and compliance with international standards in transfer pricing.
Mandatory CbC Reporting: In 2020, Ukraine introduced a three-tier structure of transfer pricing documentation, which includes CbC Reports. Following the recommendations of the Organization for Economic Cooperation and Development (OECD), this reporting model aims at comprehensive control of transactions within international groups of companies (IGC) and creating favorable conditions for business in Ukraine.
First Stage of Implementation: As of January 2, 2024, six taxpayers, acting as parent companies of IGCs, have submitted CbC Reports. These companies operate in various sectors, including oil and gas, energy, agriculture, transportation, finance, and trade.
International Context: Overall, there are 152 participants in IGCs, with only 14 not being residents of Ukraine. They are mainly represented in countries such as Austria, Belgium, Cyprus, Latvia, the Netherlands, Poland, the United States, Slovakia, and Switzerland.
Control and Responsibility: The submission and control of CbC Reports by Ukrainian residents are carried out by the State Tax Service of Ukraine in accordance with the Tax Code. In case of identified risks of non-submission or delayed submission, the regulatory authority may request clarification of information from the taxpayer.
Penalties for Violations: As of January 1, 2024, changes to the relevant provisions of the Tax Code have come into effect, prescribing penalties for non-submission or delayed submission of CbC Reports. Liability for these violations can be rectified by providing clarification and timely submission of corrected documents. Crowe Erfolg Ukraine welcomes the first step in implementing CbC Reports in Ukraine and is ready to provide necessary support to companies to ensure the accuracy and timely submission of essential documents. Our team is prepared to collaborate with businesses to ensure compliance with all requirements and international standards in the field of financial reporting
