A foreign company is recognized as a CFC if the controlling person: - owns a stake in a foreign legal entity in the amount of more than 50 percent, or - owns a stake in a foreign legal entity in the amount of more than 10 percent, provided that several individuals - residents of Ukraine and/or legal entities - residents of Ukraine own stakes in a foreign legal entity, the size of which in aggregate is 50 percent or more, or - individually or together with other residents of Ukraine - related persons exercises actual control over the foreign legal entity.