JURIMEX offers a wide range of tax and legal services in the area of international taxation, cross-border operations and transfer pricing, including, but not limited to:

• tax structuring of investments and of project financing in Ukraine and abroad, including through the network of foreign law and tax firms which JURIMEX is a member of;

• comprehensive tax support of M&A transactions, including, without limitation, tax diagnostics (reviews) of businesses in connection with their acquisitions or sales, tax structuring of M&A transactions and financing thereof, tax aspects of SPAs, tax reporting in respect of M&A transactions, M&A tax advisory and representation in discussing the tax aspects of M&A transactions;

• comprehensive tax and legal support to align the corporate structures and cross-border operations of Ukrainian companies and their beneficiaries with the MLI requirements and other BEPS actions;

• comprehensive tax and legal support to Ukrainian beneficiaries and their business structures in accessing the international capital markets;

• advice, tax compliance and reporting, legal support and representation in connection with tax audits and administrative and judicial appeals of tax assessments on transfer pricing and international tax matters. In particular, such advisory and legal assistance may relate, without limitation, to: permanent establishments of non-residents in Ukraine and specifics of their taxation, the application of double taxation agreements, including enjoyment of tax benefits, compliance with the beneficial ownership, principal purpose test (PPT), tax non-discrimination and other requirements.

• preparation of requests and receipt of tax rulings on international taxation and transfer pricing issues;

• tax planning for individuals and advice on tax reporting and compliance, residence, taxation of income from Ukrainian and foreign sources, controlled foreign companies (CFC) and other aspects of international taxation;

• advice and legal assistance in connection with the international exchange of financial and tax information;

• advice on whether Ukrainian ultimate beneficial owners and their structures abide with the tax and other laws for the internal compliance purposes of Ukrainian and foreign banks;

• advice and assistance in refunding excessively paid withholding tax and other taxes;

• advice and assistance in obtaining certificates of tax residence, tax payment certificates and other tax and legal documents.

Ratification of the MLI in Ukraine: taxation risks and consequences for Ukrainian businesses and their owners. 

Analytical review by Oleh Chaika