On 25 February 2026, the Ukrainian State Fiscal Service announced the 2025 deadlines for controlled foreign corporation (CFC) reporting. Resident companies must file CFC reports by 2 March together with their corporate tax returns, while individuals must submit them by 1 May alongside personal tax returns. If only an abbreviated report is filed due to delayed financial statements, a full report is due by 31 December. Taxpayers must notify authorities within 60 days of changes in CFC control and submit separate reports, including certified financial statements, for each CFC.
Ukrainian tax authority explained how advance pricing agreements work for large taxpayers. The authority confirmed that APAs can be signed before related-party transactions even start and can also be used to resolve tax disputes under double tax treaties. Once agreed, an APA stays valid even if transfer pricing rules later change. It also gives companies certainty by reducing future disputes over pricing methods, data sources, and how the arm’s length principle is applied, as long as the transactions do not change. All APAs follow the OECD transfer pricing guidelines.