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Ukraine Confirms CbC Report Local Filing Required for U.S. MNE Group

01 April 2025

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Approved Changes

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Ukraine-United States

The State Tax Service Of Ukraine recently issued a guidance letter (individual tax consultation) dated 12 March 2025 on whether a constituent entity in Ukraine is required to submit a CbC report on behalf of its U.S. parented MNE group (secondary local filing) for the fiscal year running from 1 September 2024 to 31 August 2025. The letter clarifies that the secondary local filing requirements apply for the first time for reporting fiscal years beginning on or after 1 January 2024 given that CbC Multilateral Agreement (MCAA) entered into force for Ukraine on 4 July 2024 (requirements apply from the...