Ukraine

First reporting fiscal year: Ending in the period from 1 January to 31 December 2022 for Ukrainian resident MNEs. (Beginning in the period from 1 January to 31 December of year when the MCAA will be activated for non-resident MNEs)

Consolidated group revenue threshold: EUR 750 million

Filing deadline: 12 months following the end of the reporting fiscal year

Local filing required: Requirement suspended

Surrogate parent entity filing permitted: Yes

First review of the domestic legal framework: 2020/2021

Ukraine’s 2020/2021 report recommended that Ukraine amend its legislation or otherwise take steps to ensure that the definition of MNE Group is in line with that required in the Action 13 standard. Ukraine has amended this definition and this recommendation is therefore removed. 1

Ukraine’s 2020/2021 report recommended that Ukraine amend its legislation or otherwise takes steps to ensure that local filing is only required in the circumstances contained in the terms of reference. Ukraine has suspended local filing until further notice, and this recommendation is therefore removed. 2

Ukraine’s 2020/2021 report recommended that Ukraine clarify that the annual consolidated group revenue threshold calculation rule applies in line with the OECD guidance on currency fluctuations in respect of an MNE Group whose Ultimate Parent Entity is located in a jurisdiction other than Ukraine. Ukraine has issued guidance making this clarification and this recommendation is therefore removed. 3

Ukraine’s domestic legal and administrative framework meets all terms of reference.

Ukraine has no bilateral relationships in place for the exchange of CbC reports nor processes to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework.

It is recommended that Ukraine take steps to have qualifying competent authority agreements in effect with jurisdictions of the Inclusive Framework that meet the confidentiality, consistency and appropriate use conditions and with which Ukraine has an international exchange of information agreement in effect that allows for the automatic exchange of tax information. This recommendation remains in place since the 2017/2018 peer review.

Ukraine’s 2018/2019 report recommended that Ukraine take steps to implement the necessary processes or written procedures to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework. Further information has been received showing that these processes are in place and this recommendation is now removed.

Ukraine’s 2017/2018 report recommended that Ukraine take steps to ensure that the appropriate use condition is met ahead of the first exchanges of information. Ukraine has provided details of the controls it has in place to ensure the appropriate use of CbC reports, which comply with published Guidance on the Appropriate Use of Information Contained in CbC Reports.

Metadata, Legal and Rights

This document, as well as any data and map included herein, are without prejudice to the status of or sovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Extracts from publications may be subject to additional disclaimers, which are set out in the complete version of the publication, available at the link provided.

© OECD 2023

The use of this work, whether digital or print, is governed by the Terms and Conditions to be found at https://www.oecd.org/termsandconditions.