The adjusted profit of a CFC is exempt from taxation under the following conditions: • There is an agreement on the avoidance of double taxation or on the exchange of information between Ukraine and the country of location (registration) of the CFC and: - the CFC pays income tax at an effective rate not less than the basic (basic) rate of corporate income tax in Ukraine (18%) or is less by no more than five percentage points, or - the share of passive income of the CFC does not exceed 50% of the amount of its total income from all sources; • The total combined income of all CFCs of one controlling person from all sources does not exceed EUR 2 million at the end of the reporting period; • the CFC is a public company, the shares (units) of which are traded on a recognized stock exchange; • CFC is an organization that carries out charitable activities and does not distribute income for the benefit of its founders (participants) (clause 39-2.4,  of the Tax Code).