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Tax
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  • Nataliya Tomashevskaya
    Partner practice

    Tax

    Implementation of investment projects and business schemes in Ukraine as well as transnational transactions involving Ukrainian residents requires careful preliminary tax analysis, structuring and planning in order to minimize the tax burden.

    Moreover, taxpayers’ rights are now more and more frequently restricted as far as tax credit and similar issues are concerned; governmental services refer fairly often to acts, instructions, and letters explaining their position as per the application of some or other fiscal rules in violation of laws; the legislation contains rules which may be ambiguously interpreted and such interpretation may adversely affect the implementation of certain transactions. Notwithstanding such trends, there is a great deal of ways to protect taxpayers’ and investors’ rights which are extensively practiced.

    For example, the litigation practice proves that the most court cases are ultimately resolved in favor of taxpayers rather than the tax service. In this case, however, it is crucial for successful litigation proceedings to have proper legal support and competent experts representing taxpayers. Likewise, diligent structuring of a transaction with a resident or foreign investor will enable to reduce significantly tax risks, identify adverse effects the parties may sustain, and to avoid potential problems.

    Considering the above, INTEGRITES offers the following services in this field:

    • Tax advising of residents and foreign companies on day-to-day business, including taxation rules in foreign countries and application of double taxation treaties;
    • Tax structuring, developing schemes to minimize taxation, tax planning for investment projects;
    • Tax due diligence of companies, structuring transactions for sale and purchase of legal entities, fixed assets and transfer of liabilities;
    • Representing clients before fiscal authorities, administration courts in relation to taxation rules and application of other compulsory payments.

  • Tax. Projects.

    Tax advising of residents and foreign companies on day-to-day business, including taxation in foreign countries and application of double taxation treaties.

    • Advising on day-to-day business in compliance with the rules governing VAT and profit tax, excise duty, customs duty, withholding, land, dividend and other taxes, and compulsory payments to the budget and special-purpose funds.
    • Issuing legal opinions as per the identified risks arising out upon application of certain taxation and accounting rules.
    • Advising on double taxation treaties and the specifics of foreign tax laws.

    Tax structuring, developing schemes to minimize taxes, tax planning and legal analyses of legislative aspects in investment projects.

    • Structuring commercial transactions, projects of various levels, developing operating structures of companies in the framework of investment programs, including international transactions and transactions made through the territories with the simplified tax treatment.
    • Tax structuring, establishing minimization schemes, planning transactions to be implemented either within Ukraine or as a part of transnational schemes, establishing the risk management system.

    Tax due diligence of companies, structuring transactions for sale and purchase of legal entities and fixed assets, and transfer of liabilities.

    • Legal due diligence of companies under specific instruction of the purchaser or the seller to identify tax risks, and developing recommendation to minimize tax risks;
    • Structuring M&A transactions, transactions for replacing the debtor, purchasing fixed assets, integral property complexes, liquidation of companies, sale of assets upon implementation of bankruptcy proceedings following tax optimization schemes and rules for tax exemption in relation to a number of transactions;
    • Drafting documents related to implementation and closing of transactions, including sale and purchase transactions.

    Representing clients before fiscal authorities and administration courts in relation to taxation rules and application of other compulsory payments.

    • Representing clients before fiscal authorities, including tax and customs authorities, special purpose funds, administration courts in relation to the procedure and terms and conditions for applying taxes and other compulsory payments.