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Controlled Foreign Companies (CFCs): Reporting and Taxation Rules for Ukrainian Owners in 2026

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This lecture by Petro Krychun offers a concentrated dose of practical insights from a tax consultant and expert who deals firsthand with the challenges Ukrainian owners face regarding CFC (Controlled Foreign Company) reporting.
By the end of 2026, the topic of CFCs will once again cease to be a mere "formality." The State Tax Service is already actively receiving data via CRS (Common Reporting Standard) exchanges, and initial court rulings—which will shape future administrative practices—are beginning to emerge. Fortunately, fines and audits for owners of foreign companies will become a reality a bit later—once the war is over. However, that future could prove painful; when the time comes to report for all the intervening years, gathering the necessary information may turn into a major and costly challenge.
Who should attend?
Owners and beneficiaries of foreign companies, partnerships, and trusts; CFOs and financial directors of groups with foreign assets; tax consultants and lawyers; auditors; and investors holding foreign stock portfolios, real estate, or crypto assets.
What we will cover:
<ul>
<li>What is a CFC, and how do you determine who qualifies as a "controlling person" (CP) and when they are required to file reports with tax authorities? </li>
<li>Why does the issue of "relatedness" between individuals remain unresolved in the context of CFC regulations? What is the difference between legal and de facto control over a CFC?</li>
<li>CFC notifications: who must file them, and in which cases?</li>
<li>What reports must CPs file, and by what deadlines? </li>
<li>When should an abridged and/or full CFC report be submitted?</li>
<li>Does a tax liability always arise, and what tax exemption criteria apply in Ukraine? </li>
<li>How do you correctly calculate adjusted profit and the taxable base?</li>
<li>Taxation of pass-through dividends as a legal scheme for optimization and repatriating income—but for how long?</li>
<li>Practical aspects of completing the CFC report and the asset declaration. Key problem areas and "costliest" pitfalls in CFC reporting, along with recommendations for addressing them.</li>
<li>What additional issues and risks are highlighted by recent administrative practices regarding CFCs?</li>
</ul>

Teacher, economist, lawyer, accountant, Owner & CEO of TCG Consulting, President of the NGO "Federation of Professional Accountants and Auditors" / PhD, MBA

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Petro Krychun

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Master of Business Administration is a qualification much sought after by current business leaders worldwide. The program helps to understand in-depth and master management competencies with the special focus on project management 
MBA is accredited by the PMI Global Accreditation Center for Project Management Education Programs (GAC)) 
Language of instruction: Ukrainian

MBA Program

The program helps to understand in-depth and master management competencies

This program designed for business owners and top executives assist in identifying new business opportunities based on experience and knowledge acquired in the business school

SE MBA Program 

The program forms strategic thinking and vision

This mid-term program caters to those who need to master the fundamentals of running a business 
Language of instruction: Ukrainian

Pre-MBA Business Program

This mid-term program caters to those who need to master the fundamentals of running a business

A medium-term program for the development of key competencies in the field of finance, which increases qualifications in solving strategic and operational financial problems, assessing and forecasting the financial state of the organization, determining the means of financial support for the implementation of the strategic goals of the enterprise 
Language of instruction: Ukrainian

pre-MBA Finance Program

Mid-term program for the development of key competencies in the field of finance

Mid-term program assists in mastering managerial tools and implementing strategies professional and personal transformation 
Language of instruction: Ukrainian

pre-MBA Leadership Program

Mid-term program assists in mastering managerial tools and implementing strategies professional and personal transformation

Mid-term program assists in mastering managerial tools and implementing strategies professional and personal transformation 
Language of instruction: Ukrainian

Controlled Foreign Companies (CFCs): Reporting and Taxation Rules for Ukrainian Owners in 2026

Conducts

Petro Krychun

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MBA

SE MBA

pre-MBA Business

pre-MBA Finance

pre-MBA Leadership

pre-MBA Marketing