Ukraine now has automatic exchange of country-by-country reports for multinational groups with 99 countries. The mechanism is part of international tax transparency and transfer pricing control, but it is not yet active with several jurisdictions.
The State Tax Service says automatic CbC exchange does not currently function with Canada, Vietnam, Israel, Kazakhstan, Nigeria, Botswana, Cabo Verde, Gabon, Greenland, Haiti, Mauritania and Morocco. A bilateral arrangement with the United States has also not yet been signed.
What CbC reporting shows
Country-by-country reporting gives tax authorities a structured view of how multinational groups distribute revenue, profits, taxes paid and economic activity across jurisdictions. It helps identify whether profits are aligned with real activity or shifted through corporate structures.
For Ukraine, the exchange is one more tool in transfer pricing oversight. It does not replace audits or local documentation, but it gives tax authorities a broader international picture when assessing large groups.
Why some countries are outside
Automatic exchange between two jurisdictions starts only after both sides complete legal and technical procedures. If requirements are not finished, the mechanism is temporarily not applied under the multilateral CbC agreement.
Ukraine signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports on 3 November 2022. The agreement officially entered into force for Ukraine on 4 July 2024.
By April, Ukraine had received CbC reports from 29 countries for the 2024 financial year. Overall, automatic exchange had delivered data from 35 foreign partners on more than 700 multinational groups. The expansion to 99 active partners shows Ukraine moving deeper into global tax data infrastructure, even as important gaps with the United States and Canada remain.
