Do Ukrainian CFC rules apply to my Cyprus company?
Short answer
They can, while you are a Ukrainian tax resident. A foreign company is controlled if a Ukrainian resident owns more than 50%, or more than 10% when Ukrainians together own 50% or more, and the owner files a CFC report.
The profit is exempt where Ukraine has a tax treaty with the company's country, as it does with Cyprus, and either the company's effective tax is no more than five points below Ukraine's 18%, or its passive income is half or less of its income. A Cyprus company paying the 15% corporate tax normally passes the first test.
All of one person's controlled companies are also exempt if their combined income is €2 million or less. The Ukraine–Cyprus treaty, signed in 2012, has been in force since 2013, with a protocol in force since 2019.
Sources
- Tax Code of Ukraine (zakon.rada.gov.ua) zakon.rada.gov.ua
- Cyprus Ministry of Finance: double tax treaties mof.gov.cy
Information, not advice. This answer describes the published rules as they stand on 12 October 2026, checked against the sources listed. Tax and residence rules depend on your own circumstances and change; check your position with a tax adviser qualified in Ukraine and in Cyprus before you act on it.
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