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Tax Disputes

Why PwC Legal Ukraine?

  • Our Tax Dispute Resolution team is a part of a network of 2,500 lawyers in over 80 countries, advising an extensive client base, which includes Fortune Global 500 corporations, multinationals, large privately held businesses and mid-market companies 
  • Being part of the PwC Legal global network we exchange global experience, incorporate cutting-edge dispute resolution techniques and enhance our practice by using international best practices in the area of our expertise
  • Our unique relationship with legal and tax experts, business consultants and other service providers within the global PwC network allows our clients to benefit from a truly comprehensive and multifaceted approach to resolving tax disputes. It allows us to meet the new challenges and confidently resolve the most complicated tax disputes by using sophisticated methods
  • Our team consists of experienced attorneys-at-law, being socially responsible and adhering to the highest professional and ethical standards



In Ukraine the firm provides legal services to a number of international businesses as well as domestic companies. In particular, Tax Dispute Resolution team has been providing its services to the companies and representative offices operating in such markets as IT, agriculture, automobile, energy, FMCG, financial, electronics, pharmaceuticals and healthcare, etc. Our team is also actively engaged in public projects, including support to the Ministry of Finance of Ukraine in drafting legislative concepts aimed at improvement of tax legislation in Ukraine.

Scope of Services

The scope of services provided by our Tax Dispute Resolution team includes legal assistance and advice on the following matters:

Prevention of as well as preparation for a tax dispute

  • Legal analysis of primary and supporting documents and legal position of a company with regard to the principal transactions and/or approaches in the tax reporting
  • Evaluation of risks based on results of the mentioned analysis, including evaluation of chances to succeed in a potential tax dispute
  • Recommendations aimed at mitigation of uncovered risks for previous and future periods, development of the “defence file”
  • Practical advice on tactics and strategy of preparing for and conducting tax dispute
  • Tax and legal support during the tax audit, including addressing the tax authorities’ requests
  • Assistance with receiving tax clarifications

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Support in challenging tax authorities’ decisions in the administrative appeal procedure

  • Drafting objections to tax audit reports
  • Drafting claims on tax notification-decisions, tax demands, and other decisions by the tax authorities
  • Representing the clients’ interests before the tax authorities of all levels

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Support in challenging tax authorities’ decisions, actions and lack of action in courts

  • Drafting court claims, appeals /objections to appeals, drafting cassation appeals/objections to cassation appeals
  • Representing the clients’ interests before the courts of all instances

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Enhancing clients’ tax litigation practice

  • Prioritising clients’ disputes based on designated criteria (e.g. impact on the client’s business-model, disputed amount, resources needed for the dispute resolution, etc.)
  • Strategy development for complex tax litigations
  • Development of algorithms for capturing, storing and formalizing evidence

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Selective Experience

Successful tax litigation support in challenging the multimillion tax assessments in the court procedure

Client: Winner Imports Ukraine LLC - official importer of Land Rover, Volvo, Jaguar, Porsche and Ford in Ukraine

Successful support of tax litigation that resulted in cancellation of multimillion tax assessments in two tax disputes. Furthermore, PwC Legal supported the Client with offsetting the CPT overpayment against future CPT obligations.

Client: Polpharma RO in Ukraine - the largest Polish pharmaceutical manufacturer and a leader of the Polish pharmaceuticals market

PwC Legal successfully supported the Company in a tax dispute related to challenging Client’s administrative expenses and its special CPT regime prescribed for IT companies.

Client: Cogniance LLC - Ukrainian entity of Cogniance Inc. (USA)

PwC Legal developed and successfully executed tax litigation strategy aimed at cancellation of the huge amount of tax assessments.

Client: Subaru Ukraine LLC – Ukrainian entity of the automobile manufacturing division of Japanese transportation conglomerate Subaru Corporation

Since 2009 PwC Legal has been supporting companies of the ADM Group operating in Ukraine in a number of the tax disputes (approx. 10, both in the administrative and court procedures) for the overall disputed amount of more than UAH 100 mln. These tax cases came about as a result of assessment of additional CPT, VAT, decrease of the amount of VAT refund, etc. based on results of a number of the tax audits. Moreover, PwC has been advising Ukrainian ADM Group companies on its contractual framework with the purpose to reduce tax risks.

Client: ADM - one of the world's leading processors of soybeans, corn, wheat and cocoa; its Ukrainian subsidiary is engaged in processing of sunflower seeds and considered as one of the largest companies on the market

PwC Legal successfully advised and supported the Client in a number of tax disputes aimed at offsetting huge amounts of the CPT overpayment against the tax obligations and preventing tax debt collection by the tax office.

Client: One of the largest FMCG companies in Ukraine

Contact us

Zhanna Brazhnyk

Zhanna Brazhnyk

Head of Tax Litigation

Tel: +380 44 354 0404

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