Tax services
We will provide you with quality advice and reliable support at every stage of cooperation. Our goal is to help you succeed and protect your interests.
Tax audits of companies (in particular, during M&A transactions, prior to tax inspections, or when selling/purchasing a business)
Business structuring, both in Ukraine and abroad (selection of optimal jurisdictions)
Tax audits of companies (in particular, during M&A transactions, prior to tax inspections, or when selling/purchasing a business)
Service Description:
What will the client gain?
- Reduction of tax surcharges during tax audits. A key criterion on our part is to reduce the amount of surcharges at least to a level that does not trigger criminal liability. This approach enables a more comfortable appeal process for the company and its officers.
- In the case of acquiring a company that has undergone a tax audit, understanding the amount of taxes and penalties that may need to be paid if a tax inspection takes place
Measurable outcome of the service for clients
- Amount of tax savings
- In case of a company acquisition – the amount by which the purchase price of the target company can be reduced
Who typically needs this service?
- Companies included in the official tax audit schedule, or if there are indicators suggesting a potential unscheduled tax audit
- Buyers or sellers of a business (M&A)
- New CEOs/chief accountants of a company, particularly in the context of a business acquisition
- In other cases, if there are signs of incorrect tax accounting
Business structuring, both in Ukraine and abroad (selection of optimal jurisdictions)
Service Description:
What will the client gain?
- Design/review/update of the group structure from the perspective of current tax and legal risks, as well as to ensure the use of tax benefits and legal protection of assets. In Ukraine, our team often proposes models involving investment funds (CIFs or UIFs).
Measurable outcome of the service for clients
- Reduction of tax and legal risks, amount of tax savings
Who typically needs this service?
Large and medium-sized businesses
Foreign bank accounts and transferring funds to foreign accounts under foreign economic activity (FEA) restrictions
Assessment of the legality of opening such accounts, their usability, and reduction of tax risks
Appealing tax audit results – pre-trial and judicial appeals
Foreign bank accounts and transferring funds to foreign accounts under foreign economic activity (FEA) restrictions
Service Description:
What will the client gain?
Understanding of tax/currency risks and ways to mitigate them when using foreign bank accounts. Legal methods for crediting funds to foreign accounts.
Measurable outcome of the service for clients
- Amount of foreign exchange difference
Who typically needs this service?
- Large and medium-sized businesses, IT companies, and companies from other sectors that relocate their sole proprietors/employees abroad
Appealing tax audit results – pre-trial and judicial appeals
Service Description:
What will the client gain?
- Reduced tax assessments following the audit
Measurable outcome of the service for clients
- Amount of tax savings
Who typically needs this service?
- Companies undergoing tax audits
Support during tax audits
Obtaining individual tax rulings based on a prepared request
Support during tax audits
Service Description:
What will the client gain?
- Lower amounts of additional tax assessments following the audit. A key criterion for us is reducing the assessed amount to at least a level that does not trigger criminal liability. This approach enables further appeals in a more favorable format for the company and its officers.
Measurable outcome of the service for clients
- Amount of tax savings
Who typically needs this service?
- Companies undergoing scheduled or unscheduled documentary audits, as well as factual audits.
Obtaining individual tax rulings based on a prepared request
Service Description:
What will the client gain?
- Predictability in situations that are not clearly regulated by the Tax Code of Ukraine, and protection from tax assessments. A distinctive feature of our team’s approach is that we prepare not only the request itself but also a substantiated draft of the expected response.
What client problems does this service solve?
- In the presence of an individual tax consultation, the tax authorities will have no grounds to assess additional taxes or impose penalties
Who typically needs this service?
- Any taxpayer
Obtaining certificates from the Chamber of Commerce and Industry (for tax, contractual purposes, or to avoid FEA penalties)
Used to obtain exemption from penalties for violating FEA settlement deadlines, from VAT on destroyed assets during wartime, and from liability for breach of contract
Diia.City – full support, from assessing eligibility and feasibility of applying the regime, to onboarding under Diia.City, drafting gig contracts, preparing inquiries to the Ministry of Digital Transformation, and more
Support with onboarding a company into the Diia.City regime, calculation of tax savings, etc.
Obtaining certificates from the Chamber of Commerce and Industry (for tax, contractual purposes, or to avoid FEA penalties)
Purpose: To obtain exemptions from penalties for violations of foreign economic (FE) settlement deadlines, from VAT on destroyed assets during the war, and from liability for breach of contract
Service Description:
What will the client gain?
- Exemption from FE penalties, additional VAT charges, and liability for breach of contract
Measurable outcome of the service for clients
- Amount of saved FE penalties, VAT assessments, and contractual fines
Who typically needs this service?
- Medium and large companies that:
- Made advance payments to non-residents for goods/services and did not receive them within the foreign currency control deadlines, particularly due to the war;
- Exported goods and did not receive payment within the foreign currency control deadlines, particularly due to the war
- Were affected by the war and lost assets (looting, missile strikes, drone attacks, etc.)
- Violated contract terms due to force majeure circumstances
Diia.City – full support, from assessing eligibility and feasibility of applying the regime, to onboarding under Diia.City, drafting gig contracts, preparing inquiries to the Ministry of Digital Transformation, and more
Service Description:
What will the client gain?
- Salary tax savings, corporate income tax savings (in case of applying the Distributed Profit Tax regime), reduction of tax/labor risks (especially if the previous model involved sole proprietors).
A key advantage of our team is our involvement in drafting the relevant legislative and tax framework that introduced the Diia.City regime, as well as our active participation in leading IT associations (EBA IT Committee, Kharkiv IT Cluster).
Measurable outcome of the service for clients
- Amount of tax savings, amount of penalties avoided, and reduction in applicable risks
Who typically needs this service?
- IT and non-IT companies where the number of IT specialists (employees or Sole proprietors) exceeds 9 people and their average income exceeds €1,200
Construction financing models under changes in tax legislation
Advisable for optimizing financing structures in the context of evolving tax regulations
Company reorganizations (mergers, spin-offs, etc.)
Optimization of taxation within a group of companies, restructuring of the group, and intra-group asset transfers
Construction financing models under changes in tax legislation
Service Description:
What will the client gain?
- Incorporation of new tax rules and access to tax benefits when implementing construction projects
Measurable outcome of the service for clients
- Amount of tax savings achieved through proper implementation of the construction project
Who typically needs this service?
- Developers, construction project owners
Company reorganizations (mergers, spin-offs, etc.)
Service Description:
What will the client gain?
- Consideration of optimal tax burden for group structuring and asset transfers
Measurable outcome of the service for clients
- Amount of tax savings achieved through proper implementation of the project
Who typically needs this service?
- Medium and large companies
Legislative advocacy
Advisory support and lobbying for changes and/or new initiatives in legislation
Registration of non-residents as corporate income taxpayers and VAT payers in Ukraine
Advisable for optimizing taxation within a group of companies and eliminating non-resident income tax
Legislative advocacy
Service Description:
What will the client gain?
- Preparation of economic analysis on the potential impact of legislative changes in Ukraine, assessment of international experience, communication with relevant parliamentary committees, broad articulation of unresolved or insufficiently regulated issues, drafting of legislative proposals, and support in promoting them
Measurable outcome of the service for clients
- Resolution of the identified issue at the level of Ukrainian legislation
Who typically needs this service?
- Medium and large companies, business associations
Registration of non-residents as corporate income taxpayers and VAT payers in Ukraine
Service Description:
What will the client gain?
- Optimization of the tax burden for group structuring and elimination of non-resident income tax within the group (withholding tax on repatriation)
Measurable outcome of the service for clients
- Amount of tax savings achieved through proper implementation of the project
Who typically needs this service?
- Medium and large companies, corporate groups with holding structures
CFC (Controlled Foreign Company) – preparation of CFC reports, assessment of CFC-related tax consequences, and evaluation of international structures from a CFC perspective
Comprehensive support on CFC matters: assessment of corporate groups and structuring from a CFC perspective, preparation of CFC reports
Tax optimization (disposal of real estate, corporate rights, use of CIFs in the business structure, etc.)
Qualified tax optimization within a group of companies from operations in Ukraine, reduction of the group’s tax burden, and legal income generation for the ultimate beneficial owner (individual) in Ukraine
CFC (Controlled Foreign Company) – preparation of CFC reports, assessment of CFC-related tax consequences, and evaluation of international structures from a CFC perspective
Service Description:
What will the client gain?
- Structuring of corporate groups to reduce CFC-related risks. Assessment of existing CFC risks and their mitigation. Completion of CFC reports.
A key advantage of our team is our involvement in drafting the legislation that introduced the CFC regime, as well as our participation in subsequent working groups.
Measurable outcome of the service for clients
- Legitimate reduction of tax burden under CFC rules, compliance with CFC reporting and tax payment obligations
Who typically needs this service?
- Owners of foreign companies
Tax optimization (disposal of real estate, corporate rights, use of CIFs in the business structure, etc.)
Service Description:
What will the client gain?
- Optimal tax burden for group structuring, reduced overall tax burden, and legal income received by the ultimate beneficial owner (individual) in Ukraine.
Measurable outcome of the service for clients
- Amount of tax savings achieved through proper project implementation; legally sourced income for the individual owner with optimized taxation
Who typically needs this service?
- Medium and large companies
Intra-group financing of companies (bond issuance, etc.)
Tax consulting
Intra-group financing of companies (bond issuance, etc.)
Service Description:
What will the client gain?
- Intra-group financing between affiliated (or related) companies with reduced risks associated with the lack of business purpose in such transactions
Measurable outcome of the service for clients
- Amount of tax savings achieved through proper implementation of the project; legitimate source of financing for the group of companies
Who typically needs this service?
- Medium and large companies
Tax consulting
Service Description:
What will the client gain?
- Expert tax consultations delivered by professionals with 15 years of experience
Measurable outcome of the service for clients
- Clarification of tax and accounting matters, recommendations for reducing tax risks, and assessment of current tax authority guidance and court practice
Who typically needs this service?
- Any taxpayer
Determination and change of tax residency
Consulting on international tax law
Determination and change of tax residency
Service Description:
What will the client gain?
- Clarity regarding the country where tax obligations must be fulfilled, or the ability to change such a country
Measurable outcome of the service for clients
- Reduction of dual tax residency risks
Who typically needs this service?
- Individuals living abroad or planning to relocate
Consulting on international tax law
Service Description:
What will the client gain?
- Access to information regarding tax and legal aspects of doing business in the target country
A key advantage — in providing such consultations, our team leverages its own experience and expertise, as well as the support of foreign partners.
Measurable outcome of the service for clients
- Legal clarity on specific transactions, structuring, and related matters
Who typically needs this service?
- Companies currently operating in or planning to enter foreign markets