📊 Only 13 per cent of controllers report on CFCs. Figures that undermine the ‘success’ of European integration

Ukrainians have been required to report on controlled foreign companies (CFCs) since 2022. For 2025, 19,000 controllers submitted reports – and the State Tax Service describes this as an improvement in tax compliance.

🔍 But if we do the maths: 24 per cent of these reports relate to Polish companies. According to business sources, Ukrainians registered 33,000 companies in Poland in 2025 alone. It turns out that 28,500 companies were not included in the reporting – and only around 13 per cent of controllers submitted reports.

⚠️ What is preventing reporting:

There is no consistent position from the State Tax Service or the Ministry of Finance regarding the tax residency of Ukrainians who have left the country due to the full-scale invasion

There is no widespread information campaign – people abroad are not within the Ukrainian information sphere, and many are still unaware of their obligation to file returns

A fiscal approach rather than one based on trust: from 2024, the State Tax Service will fine tax agents 100,000 UAH simply for being in Ukraine, interpreting this as a ‘permanent establishment’

📌 This does not encourage reporting – on the contrary, it undermines the trust that European integration is meant to build.

Svitlana Moroz’s paper “The problem of a poor tax culture in reporting on controlled foreign companies in Ukraine” at the International Scientific and Practical Conference “Implementation of European approaches to taxation and tax compliance culture in Ukraine”, organised by the Ministry of Finance of Ukraine and the State Tax University