DEGAAttorneys

Tax

Practice

Tax

With extensive experience in advising Ukrainian and international companies on tax matters, we help clients navigate complex national and international tax regulation, manage tax risks and ensure compliance with applicable law, taking into account the specifics of their business, corporate structure and commercial goals.

Our team provides comprehensive legal support on a wide range of tax matters, including tax planning, international taxation, transfer pricing, taxation of cross-border transactions and the tax aspects of corporate reorganisations, mergers and acquisitions. We help clients develop effective tax strategies tailored to their business and investment objectives. We advise on assessing and minimising tax risks, support clients during tax audits and disputes, and help resolve requests and claims from the tax authorities. Our work also covers analysing the tax consequences of business transactions, intra-group settlements and ownership structures, which makes it possible to identify potential tax liabilities in good time and ensure that business activities are properly documented.

We support clients at every stage of their business - from structuring investments and day-to-day operations to complex transactions and the resolution of tax disputes. Our approach combines in-depth legal expertise with a practical understanding of business needs, allowing us to develop effective and long-term tax solutions, minimise potential tax risks and support sustainable business growth.

Services

What can DEGA Partners offer you?

Tax advice

Analysis and assessment of tax risks

Tax structuring of investments

Tax structuring of international operations

Advice on the application of double tax treaties

Tax review and audit of contracts

Corporate tax advice

Tax audit

Transfer pricing advice

Advice on compliance with tax law and regulatory requirements

Support in tax disputes and resolution of conflicts with the tax authorities

Key experience

Our cases and projects

Tax risks of business splitting and the use of sole-proprietor models.

We analyse the tax risks associated with the use of sole-proprietor (FOP) models and with structuring a business through several business entities. We assess how independent the entrepreneurs' activities really are, the organisational and financial links between them, how the business is managed and whether the chosen model complies with tax law. We help our clients identify potential risks of their activities being requalified as artificial business splitting, additional tax assessments and penalties. Based on this analysis, we develop recommendations on optimising the business structure, properly documenting business transactions and building a tax model that reflects current regulatory requirements.

Tax liability of the director and beneficial owner: when the owner is at risk

We advise business owners, ultimate beneficial owners and company executives on tax liability and the risks associated with breaches of tax law. We analyse how powers and responsibilities are allocated between the director, the owners and other officers, and assess the risks of administrative, financial and criminal liability, in particular in cases of tax evasion, filing inaccurate returns and improper organisation of tax and accounting records.

We help clients assess the potential consequences of tax violations, support them during tax audits and disputes, and develop practical recommendations to minimise the personal risks of directors and beneficial owners. We pay particular attention to proper documentation of management decisions, internal controls, verification of business transactions and counterparties, and the risks associated with the international exchange of tax information and foreign assets.

VAT consequences of supplying services to non-residents: current practice

We advise clients on the VAT treatment of services supplied to foreign counterparties, analyse the provisions of the Tax Code of Ukraine and determine whether the relevant transactions are subject to VAT in Ukraine. Our support covers consulting, engineering and IT services, intellectual property services and other types of cross-border services, taking into account their actual substance and the specifics of each transaction.

We help clients identify and minimise tax risks, assess the positions of the tax authorities and current case law, and develop legal approaches to structuring and documenting cross-border transactions. We pay particular attention to the correct classification of services, the preparation of contractual documentation and evidence of the actual substance of business transactions. We also provide legal support in tax disputes, helping clients substantiate their VAT approach and defend their position before the tax authorities and in court.

Consultation

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