Experts Discussed the Application of CRS and CbCR in the Operations of the State Tax Service
On April 30, 2025, the Tax and Customs Law Committee of the Ukrainian Bar Association (UBA) hosted an event titled “Automatic Exchange of Information under CbCR and CRS”. The discussion attracted a wide range of participants, including representatives of the State Tax Service of Ukraine (STS).
During the event, attendees had the opportunity to review the initial outcomes of the implementation of the automatic exchange of information under the Common Reporting Standard (CRS), with a particular focus on how the STS is currently utilizing the data received. Special attention was given to the issue of Controlled Foreign Companies (CFCs) and the potential of automatic exchange mechanisms in identifying cases of tax evasion.
The submission of reports under the Country-by-Country Reporting (CbCR) framework was also addressed. Experts shared the practical challenges faced by businesses, while STS representatives provided insights into tools already being deployed to incorporate this information into tax oversight and transfer pricing analysis.
The discussion was moderated by Andriy Reun, Chair of the UBA Tax and Customs Law Committee and Head of the Tax Law Practice at LCF Law Group. Speakers included Serhii Zakrevskyi, Head of the International Automatic Exchange of Information Division of the STS of Ukraine; Yuliia Katsan, Acting Director of the Transfer Pricing Department of the STS of Ukraine; Tetiana Lysovets, Vice President of the UBA and Senior Partner at Sokolovskyi and Partners; Anton Zaderyholova, UBA Committee member and Partner at AVELLUM; and Maryna Tomash, Deputy Chair of the UBA Tax and Customs Law Committee and CEO of Tomash Consulting.
The event reaffirmed Ukraine’s steady progress toward integration into the global system of tax information exchange. The effective implementation of CRS and CbCR standards highlights the country's commitment to meeting international obligations and enhancing the transparency of its tax environment. At the same time, legal professionals emphasized the importance of clear procedures, methodological guidance, and legal certainty to ensure the effective execution of these frameworks.