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International Tax Services

Are you prepared for changes in global and Ukrainian tax landscape? 

Recent major developments in international tax regulations have drastically reshaped the global tax landscape for companies operating in multiple jurisdictions with more and more changes coming each year. Therefore, particular care should be taken when structuring cross-border transactions.

International tax issues are taking on greater significance for companies operating throughout the world. It is vital to manage your cross-border activity from an international tax standpoint, as well as to ensure compliance with legislative and regulatory requirements across different jurisdictions.

Anna Nevmerzhytska
Anna Nevmerzhytska
Director, Financial Services and
International Tax Solutions Leader

What we can do for you

We have an advanced knowledge which enables us to provide you with international tax solutions that are tailored to specific needs of your business. We are delighted to offer you services in case:

  • You need to repatriate profit and manage cash flows within a group
  • You want to be sure that you can enjoy the benefits of double tax treaties
  • You are planning cross-border acquisitions, disposals or reorganisations
  • You need to defend thin capitalisation calculations to the tax authorities
  • You are looking to raise financing or restructure existing liabilities
  • You need to manage intellectual property and intangible assets in a more tax efficient manner
  • You want to understand which of your controlled foreign companies (CFCs) may be taxed in Ukraine and how it will affect the Ukrainian business owner
  • You are struggling to choose a foreign jurisdiction where you could expand your business

and many others...

We are ready to provide you with a wide range of complex solutions drawing on profound expertise of international taxation matters and benefit from our extensive global network of tax professionals:

Assessment of risks related to place of effective management and creation of permanent establishments

Advising upon planning of the financial flows, elaboration of operational, holding, financial and IP structures and modelling related tax burden

Reviewing group structures and identifying their weak spots in light of the latest tax initiatives in Ukraine and across the globe

Elaboration of a defense file to support the eligibility for reduced tax rates and other tax treaty benefits, including evidencing the beneficial owner status and compliance with the principal purpose test

Support in set-up and tuning of internal bank procedures to comply with the initiatives on tax information exchange (FATCA, CRS)

Identification of issues worth solving via mutual agreement procedures and assistance with related practical matters

Comparison of options for financing the business

Modeling the tax impact of CFC rules on the tax liabilities of the Ukrainian controlling person

Pre- and post-M&A structuring

 risk red

Assessment of risks related to place of effective management and creation of permanent establishments

 decisions red

Advising upon planning of the financial flows, elaboration of operational, holding, financial and IP structures and modelling related tax burden

DAMIL 123757 132 red

Reviewing group structures and identifying their weak spots in light of the latest tax initiatives in Ukraine and across the globe

 document sections red

Elaboration of a defense file to support the eligibility for reduced tax rates and other tax treaty benefits, including evidencing the beneficial owner status and compliance with the principal purpose test

 question red

Support in set-up and tuning of internal bank procedures to comply with the initiatives on tax information exchange (FATCA, CRS)

 agreement deal red

Identification of issues worth solving via mutual agreement procedures and assistance with related practical matters

Contact us

Anna Nevmerzhytska

Anna Nevmerzhytska

Director, PwC Ukraine

Tel: +380 44 354 0404

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