Ukraine and Israel are still without automatic CbC exchange — what does this mean for business

Ukraine has already launched automatic exchange of Country-by-Country Reporting with 99 countries worldwide, but Israel remains among the states with which this mechanism has not yet come into effect.

This is important news not for the general audience, but for a specific circle: international corporate groups, tax consultants, lawyers, accountants, and businesses operating between Ukraine, Israel, the USA, the EU, and other jurisdictions.

According to the publication ‘Law and Business’ dated May 18, 2026, citing the State Tax Service of Ukraine, the automatic exchange of CbC reports is already in effect between Ukraine and 99 countries. However, between Ukraine and a number of states, including the State of Israel, such exchange has not yet begun to apply.

What happened and why Israel ended up on the list

CbC is the reporting of international corporate groups by country. Such reports disclose where the group earns income, where it shows profit, where it pays taxes, and in which jurisdictions it conducts real economic activity.

For tax authorities, this is one of the tools for controlling transfer pricing.

In other words, the state looks not only at an individual company within its country but at the entire international structure: where assets, employees, revenue, profit, taxes, and management centers are located. This helps to identify schemes where profit may be artificially shifted to more favorable tax jurisdictions.

Ukraine signed the Multilateral Competent Authority Agreement on the automatic exchange of CbC reports on November 3, 2022, and it officially came into force for Ukraine on July 4, 2024.

But the mere signature under the multilateral agreement does not mean that the exchange automatically started with all countries simultaneously.

To launch the exchange between specific states, both parties must complete legal and technical procedures. Until this is done, the mechanism is temporarily not applied specifically in relations between these countries.

With whom the exchange is not yet in effect

In the Ukrainian list of countries and territories with which the automatic exchange of CbC has not yet come into force, Canada, Vietnam, Israel, Kazakhstan, Nigeria, Botswana, Cape Verde, Gabon, Greenland, Haiti, Mauritania, and Morocco are indicated.

It is separately noted that Ukraine has not yet signed a bilateral agreement on the automatic exchange of CbC with the USA.

For Israel, this does not mean ‘tax isolation’ and certainly does not mean a lack of cooperation with Ukraine in other formats. It is specifically about the specific mechanism of automatic exchange of reports of international corporate groups by country.

But for business, the wording is still important.

If an international structure has Ukrainian and Israeli elements, owners, directors, and consultants need to understand which data is automatically transmitted, which is not yet transmitted through the CbC mechanism, and which may be requested or disclosed through other tax and legal channels.

Ukraine, Israel, and the transparency of international business

The Ukrainian-Israeli business connection has become much more noticeable in recent years. There are companies whose owners, management, employees, contractors, assets, or clients are located in several countries at once. Some of these structures are related to IT, trade, medical services, online services, consulting, real estate, logistics, and investment projects.

Against this background, tax transparency becomes not a technical topic but a part of business security.

Automatic exchange of CbC is primarily needed by large international groups. But its logic has a broader impact: states are increasingly checking where real value is created, where decisions are made, where people are located, and why profit ends up in one jurisdiction or another.

For Ukrainian businesses working with Israel, this means the need to build documentation, contracts, management logic, and tax position in advance. For Israeli companies with a Ukrainian direction — the same, only from the other side.

In the middle of this topic for NANews — Israel News | Nikk.Agency, the practical meaning is important: Ukraine and Israel remain connected not only by politics, war, repatriation, and humanitarian issues but also by business. And business in such a connection needs clear rules, predictability, and understanding of where ordinary planning ends and tax risk begins.

Why this is not a reason to relax

The absence of automatic exchange of CbC between Ukraine and Israel at the current stage should not be perceived as a ‘window of invisibility’.

Firstly, it is only about one type of reporting.

Secondly, the international tax environment is changing rapidly. What is not yet technically or legally launched today may start working tomorrow after the completion of procedures.

Thirdly, tax authorities can use other mechanisms for exchanging information, requests, documents from banks, audit data, open registers, corporate reporting, and materials submitted by the companies themselves.

Therefore, for international groups, the main conclusion is not that the exchange with Israel is not yet in effect, but that they need to prepare for a more transparent environment in advance.

What companies and consultants should consider

The State Tax Service of Ukraine recommends considering the current status of international information exchange when planning activities, preparing reports, and controlling transfer pricing.

For business, this means several practical questions.

It is necessary to understand whether the company is part of an international group, whether it falls under the CbC rules, where the parent structure is located, in which country the report is submitted, which group companies operate in Ukraine or Israel, and how functions, risks, assets, and profits are distributed.

It is also important not to confuse CbC with regular tax reporting. This is not a small business declaration and not a standard report of an individual company. It is a tool for large international groups, but it affects the overall culture of tax control.

For companies with a Ukrainian-Israeli contour, it is especially important not to wait until the mechanism fully operates between the two countries. It is wiser to check the structure, intra-group agreements, pricing, management functions, and evidence of real economic activity in advance.

The Israeli angle: why the news is important right now

Israel is a country with a strong technology sector, international investments, and a large number of companies operating in several markets at once. Ukraine, despite the war, maintains a significant IT base, entrepreneurial activity, service exports, and connections with the diaspora.

At the intersection of these two economies, many hybrid structures arise: Ukrainian teams work for Israeli companies, Israeli entrepreneurs collaborate with Ukrainian contractors, some owners or specialists change their country of residence, and business continues to serve clients in different jurisdictions.

Here, tax transparency becomes a matter not only of law but also of reputation.

If a company operates carefully, documents decisions, shows the real logic of profit distribution, and does not try to mask artificial schemes, new mechanisms for exchanging information should not become a shock. If the structure relies on gray agreements, risks will increase.

While the automatic exchange of CbC between Ukraine and Israel is not in effect. But the direction of movement is already clear: the international tax system is becoming increasingly interconnected, and states are less willing to take businesses ‘at their word’.

For Ukrainian-Israeli companies, this is a signal not for panic, but for order.