Over 58,000 CFC Reports Filed: Geography, Taxes, and Key Insights
The State Tax Service of Ukraine has published preliminary results of the Controlled Foreign Company (CFC) reporting campaign. From 2022 to 2024, a total of 58,220 CFC reports were submitted, including 19,162 in 2024 alone. GLS Law is proud to have been among the first to guide clients through this new legal and tax compliance challenge.
📌 Who Filed Reports?
- 98% of reports were filed by individuals.
- Only 2% came from legal entities.
This confirms that CFC obligations primarily affect entrepreneurs, investors, IT professionals, and expats who have established companies abroad.
📍 CFC Geography — Where Do Ukrainians Incorporate?
Most popular jurisdictions:
- 🇵🇱 Poland — 23%
- 🇨🇾 Cyprus — 10%
- 🇺🇸 USA — 10%
- 🇬🇧 United Kingdom — 10%
- 🇪🇪 Estonia — 9%
- 🌍 Other countries — 38%
This trend highlights a preference for transparent, stable, and accessible jurisdictions — but also underscores: the country of incorporation is not just about taxes, but also about reporting obligations and legal responsibility.
💰 How Much Was Paid in Taxes?
- Total CFC-related tax liabilities (2022–2024): UAH 4.9 billion.
- For 2024 alone: UAH 2.9 billion.
This demonstrates not only a functioning system, but also a strong fiscal impact and growing awareness among Ukrainian taxpayers.
🛠 What If There Are Errors?
The tax authority reminds taxpayers: you may correct CFC reports voluntarily under subpara. 69.38 of para. 69, Section XX of the Tax Code of Ukraine. Proactive correction is far better than post-factum audit exposure.
GLS Law is already assisting in dozens of such cases — from technical fixes to full structural overhauls.
🎯 Our Role in the CFC Campaign
At GLS Law, we are proud to have been a trusted partner for clients filing CFC reports for the first time. We:
- assessed ownership structures;
- verified reporting obligations;
- prepared and submitted reports;
- advised on tax implications and planning strategies.
For us, CFC reporting is not an endpoint — it’s the foundation for strategic international tax planning and secure business structures.
📌 Uncertain about your CFC report or haven’t filed yet? Contact GLS Law — we will help you comply today and build resilience for tomorrow.
