Fines for a controlled foreign company (CFC)

Non-submission by the controlling person of the notification of the acquisition of a share in CFC incurs a fine of 300 times the subsistence minimum for an able-bodied person (as of 01.01.2023 - UAH 805,200).
Failure to submit a report on CFC results in a fine of 100 times the subsistence minimum for an able-bodied person (as of January 1, 2023 - UAH 268,400).
Untimely submission of the CFC report incurs a fine of one time the subsistence minimum (as of 01.01.2023 - UAH 2,684) for each calendar day of non-submission, but not exceeding 50 times the subsistence minimum (as of 01.01.2023 - UAH 134,200).
Non-representation of information on existing CFCs in the report results in a fine of 3% of the CFC income or 25% of the adjusted CFC profit for the year, whichever is greater, but not exceeding 1000 times the subsistence minimum (as of 01.01.2023 - UAH 2,684,000) for each instance.
Failure to submit a report within 30 calendar days after the deadline for payment of financial sanctions (fines) incurs a fine of five times the subsistence minimum (as of January 1, 2023 - UAH 13,420) for each calendar day of failure to submit a report, but not exceeding 300 times the subsistence minimum (as of January 1, 2023 - UAH 805,200).

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Analyze whether the rules of the CFC apply to you;
Determine whether there are grounds for exempting the income of the CFC from taxation in Ukraine;
Develop a work model to help reduce the tax burden;
Conduct an analysis of the financial statements of CFC and determine the adjusted profit of CFC subject to taxation in Ukraine;
Deal with CFC reporting;
Prepare a tax declaration on assets and income;
Prepare a report and notice on CFC.

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Fines of controlled foreign company (CFC)

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