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International Corporate Tax

International Corporate Tax

We help our clients to find answers and solve complex issues and tasks in the field of international corporate taxation.

We help our clients to solve issues in the field of international corporate taxation.

International corporate taxation services are an integral part of KPMG's practice of international corporate taxation and regulation of international trade in Ukraine, which is part of the professional practices in Tax and Legal department of KPMG in Ukraine with offices in Kyiv and Lviv.

We assist companies with risks mitigation in relation to international corporate taxation by providing the following services:

  • Diagnostics of business models on tax risks related to the adoption of draft law No. 1210;
  • Diagnostics and providing advice/solution on a possibility or efficiency of usage of the international agreements of Ukraine in the spheres of taxation;
  • Represent interests in regulatory authorities on the issues of international corporate taxation, in particular, in the following cases:
    • audits or procedure for appealing against the decisions, actions or omissions of the regulatory authorities;
    • preparation and provision of explanations on issues that arise during such audits or appeals;
    • review and obtaining of official documents (certificates) on audits in the regulatory authorities;
    • signing official documents (information) on the audit, and in case of any comments on the content (text) of prepared documents (certificates) – advise to sign them with a proviso;
    • preparation and submitting of written objections to acts (certificates) of such audits to controlling agencies;
    • requirements and verification of data and facts that may argue for the clients;
  • Prepare requests for obtaining and receive individual rulings of controlling agencies on the practical application of tax legislation of Ukraine on international corporate taxation;
  • Diagnostics of tax expenses related to a foreign element and provision of opinions on the effective management of the expenses, as well as support of client decisions made on the basis of such opinions;
  • Diagnostics of tax implications, compliance with other legislative requirements in relation to the change in tax status in Ukraine or abroad for activities undertaken (commercial/non-commercial) in Ukraine;
  • Comparative analysis of foreign jurisdictions on tax, customs and other factors for choosing a jurisdiction to do business in Ukraine, given recent trends on BEPS (the Action Plan on Base Erosion and Profit Shifting) and CFC (the rules for Controlled Foreign Companies);
  • Review of tax structures of the asset ownership through related entities;
  • Obtaining certificates of tax authorities on taxes paid in the Ukraine and/or abroad;
  • Identification and confirmation of the tax status of representative offices of non-residents in Ukraine;
  • Diagnostics of business models that provide for income payments to non-residents;
  • Supporting the payment of dividends, interest, royalties: diagnostics of a case and related documents, proposal for preparation and preparation of necessary documents, the communication with directors and regulatory authorities, assistance in obtaining certificates on taxes paid in Ukraine and/or abroad.

Our International Corporate Taxation professionals actively cooperate with other departments and divisions of KPMG in Ukraine, including our regional offices in Kharkiv, Lviv, and Odessa, as well as with the global network of KPMG offices in more than 150 countries. KPMG professionals employ local and global experience and opportunities of KPMG in these and other spheres and areas of corporate counselling.

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