A1 Consulting was founded in March 2021 by two partners from KPMG Law UkraineVolodymyr Chyzhykov and Mykola Mishyn. The new firm has a primary focus on tax consulting with a crucial specialization in transfer pricing (TP). Since its establishment, the team has attracted a robust clients list seeking advice in TP issues. In particular, the team acted for ADM Ukraine, one of the world’s largest grain traders to support the tax authority’s request for TP documentation for five years; supported Omya Ukraine in communications with the tax authorities regarding tax risks identified by the tax authority during analysis of TP documentation. Other clients include Valtech, Ferrexpo Poltava Mining, ZNGK, Belarusian Oil Company.

ADER HABER, a Ukrainian law firm, is known for representation of clients in tax controversies, in administrative order and courts. The firm represented a major producer and distributor of dairy products in Ukraine and foreign markets in two tax disputes appealing tax charges for USD 15.2 million. Transfer pricing audit is another area of recent queries. The tax team supported Ukrainian grain trader during an inspection concerning transfer pricing and appealing its results. Tatiana Daniltseva, partner, and Stanislav Karpov, counsel, co-head the tax practice. 

AEQUO has developed a multifaceted tax practice encompassing advisory and transactional work, as well tax controversies and litigation. The team is busy with tax planning and structuring work, deriving from its significant presence in domestic and cross-border corporate transactions and restructurings; has an active private client tax practice, sector specific tax advisory and compliance. Industry-wise the practice team works across sectors like IT, retail, finance, agriculture, consumer goods and energy. The firm has a market-leading IT practice, and is regularly retained for tax support of its projects. The firm advised Playrix, a large game development company on VAT issues related to the cross-border transfer of rights to a computer game; advised PARTS iD, Inc. on tax structuring of an employees’ option plan. Another area is tax compliance – the firm advises Motor Finance on conducting tax analysis of its structure in terms of applicability of treaty benefits under a Ukraine – Latvian double tax treaty. The firm acts for ATB Market in a dispute over input VAT, after the Ukrainian tax authorities questioned the economic substance of certain transactions entered into by ATB; continued representing ArcelorMittal Kryvyi Rih in two complex cases in which a tax authority questioned the economic substance of some of the client’s procurements of goods and services and claimed that they should be disregarded for tax purposes. The firm has expertise in the tax aspects of arbitration awards and dispute resolution proceedings. Vasyl Mishchenko, who was promoted to counsel, is focused on tax structuring of transactions and tax risk management. Mykhailo Razuvaiev joined as a senior associate from Wolf Theiss. Managing partner Denis Lysenko is the head of the firm’s tax and customs practice[1]. 

Focused exclusively on the IT industry, ALCOR advises on industry specific tax matters, getting instructions from product and IT consulting companies, large game developers, and plenty of up-and-coming Silicon Valley public companies and start-ups. The team has a focus on the operation of R&D offices in Ukraine, including tax planning and tax structuring. In particular, the firm advises Questrade, a Canadian operator of an online brokerage and stock trading services intended to offer financial independence to investors on various tax law issues related to the launch and operation of the Ukrainian R&D office; provided the US life sciences software company Insightful Science with comprehensive support for the organization of R&D in Ukraine to expand the software development business, which enables the optimization of scientific development processes based on improved methods of processing existing data. The firm arranges IT Ukraine Association with comprehensive tax and legal support as an exclusive partner on various corporate law issues related to the launch and development of its projects, including work on tax legislative initiatives. Dmytro Ovcharenko and Sergey Ovcharenko are the main point of contact. 

AMBER Law Company is known for its performance in tax disputes, especially the reinstatement of taxpayers in the status of a VAT payer and the return of funds debited to the budget from the Treasury’s VAT accounts on the fact of cancellation of the VAT payer certificate; withdrawal of taxpayers from the “risky” category in which they were wrongly classified by the tax authorities; appealing against the procedure of tax audits and their results as well as decisions made upon the results of tax audits carried out in violation of legislation; refunding wrongly/overpaid amounts of taxes and fees to the budget; appealing the refusal to register tax invoices and forcing the registration of tax invoices. Andrii Valenko is the practice head. Semen Khanin is lead partner and the main point of contact.

ANTIKA Law Firm provides legal assistance to clients in resolving tax disputes. The recent portfolio included the judicial appeal of the reduction of the budget refund on VAT and the imposition of pecuniary (financial) sanctions; challenging granting of penalties for late registration of tax invoices. The firm’s clients include industrial and mining and energy sector leaders. Alexandra Fedorenko, counsel, is the key executive figure.

The largest Ukrainian law firm, Asters, provides transactional tax advise within numerous deals handled by the big team, in particular, M&A, JVs, corporate reorganizations, debt and equity securities issues, financing, real estate matters, project financing, etc., as well as outbound tax and structuring investments of Ukrainian HNWIs into the US, Europe, and Asia. Furthermore, the firm has a vivid portfolio of tax disputes supplemented with representation in criminal proceedings related to handling allegations of tax evasion. In a recent highlight the firm acted for multinational corporations advising them on tax-wise options for entering the Ukrainian market, restructuring of business operations, numerous international tax issues, in particular, risks of permanent establishments in Ukraine, tax issues related to the implementation of stock option plans. Among sector-specific features are tax expertise in renewable energy and production sharing agreements; advice to the pharma sector in structuring relations with distributors, advice on VAT on marketing and promotion services; structuring payments models through instruments of telecom networks. The broad roster of multinational and domestic clients, including ED&F Man (Ukrainian Sugar Company), International Finance Corporation, Privatbank, Molson Coors, Toyota Ukraine, JSC Ukrainian Railways (Ukrzaliznytsia). Constantin Solyar is lead partner and head of the tax practice.

AVELLUM has an established reputation of being a legal advisor on international tax planning projects and handles transactional tax support within M&A, corporate and sovereign issues of Eurobonds. Furthermore, the firm acts for high-net-worth individuals on their wealth structuring instructions, transfer pricing and sophisticated tax disputes. The team is preferred by multinationals, Ukrainian companies, and wealthy individuals on options for investment structuring, complex tax structures, vehicles and arrangements through an investment fund or alternative structures. The team advised Lactalis Group on deal structuring and mitigation of tax risks related to the sale of some companies within the Bel Group to Lactalis Group and proposed alternative ways to mitigate exposed tax risks. The firm also assists with tax advice on the transfer of IP rights, sale-purchase of real estate, structuring market entry, taxation of dividends. The deal portfolio expands to financial services, investments, real estate, retail, trade, infrastructure, FMCG, energy, fintech and private tax mandates. Long-term clients include the Ministry of Finance of Ukraine, Jacobs Douwe Egberts Ukraine, Caterpillar Financial Ukraine. Vadim Medvedev is a tax partner and head of the private clients practice.

The Kyiv office of Baker McKenzie is consistently preferred by major multinationals seeking tax structuring in connection with their inbound and outbound investment, support of operations and business activity, advising on  tax ramifications stemming from their operating models in Ukraine. The team advised on the tax aspects of its transactional work, handled tax structuring of private wealth, international and domestic VAT planning in relation to sales structures. Additionally, the firm provides clients with transfer pricing services, including advice on transfer pricing compliance, assistance in preparation and filing of TP documentation, legal support during transfer pricing audits. The firm advised A.G.R. Group, a private agricultural innovative holding, on the acquisition of two enterprises in Kherson Region — Alpha Farm and Eurasia-Agro — from the US company AG Management Group, including on related Ukrainian tax ramifications; advising the shareholders of Biopharma on post-closure matters and associated tax ramifications after carve-out of its non-plasma business and its further sale to Stada AG. Other recent assignments included, among other things, advising on tax amnesty procedures in Ukraine, introduction of Anti-BEPS provisions into domestic legislation, change of operating models. The office has a tax disputes record, being experienced in VAT litigation. Hennadiy Voytsitskyi, tax partner, enjoys a strong market reputation. Roman Koren is an important tax team member.

CMS Cameron McKenna Nabarro Olswang offers an extensive tax offering encompassing transactional tax deriving from M&A deals and corporate reorganizations, restructuring operations in Ukraine, customs clearance and tax regimes. The tax expertise has deep industry specialism, as the global firm and Kyiv outfit are especially well-versed in advising clients from energy and utilities, IT and telecommunications, pharmaceuticals, financial sectors. The firm advised CWP Europe on the acquisition of a wind project in development, having advised on the tax implications of sale of a real estate rich company developing a wind energy project in Ukraine within the deal; continued rendering advice to Acciona Energia on tax and customs matters arising in the course of their business operations in Ukraine. Banking and finance partner Ihor Olekhov is the practice head. Viktoriia StavchukMulundkar is an important tax practitioner.

As a part of global tax practice, Dentons is retained by international corporations on tax planning and structuring, cross-border taxation, transactional tax and structuring of inbound and outbound investment and financing. Being active on the front of corporate deals, the Kyiv office ensures advice on tax aspects of recently supported M&A, and also establishing efficient tax structures and efficient customs structure for delivery and supply into Ukraine, application of double tax treaties to mitigate tax risks. The tax team advised Roku, a U.S. over-the-top streaming video platform, on tax law matters under Ukrainian legislation in connection with their international expansion in Ukraine; provided pro bono advice to an NGO – Office of Simple Solutions and Results with respect to tax reforms in Ukraine, in particular on amendments to the Tax Code of Ukraine to simplify taxation in Ukraine, and also prepared presentations and recommendations for the respective drafts of tax bills. The tax practice has two partners on board – Igor Davydenko heads the team; Ihor Mehedynyuk advised several major international clients on tax matters. Valeria Tarasenko, tax advisor, is the key member of the team. 

Ukrainian law firm ESQUIRES is skilled in supporting clients in tax and customs controversies as well as tax planning. The firm supported Hospitality Industry Group LLC in proving its right to register VAT tax invoices; represented Limagrain Ukraine LLC in appealing against tax notices and imposition of penalties for violating terms for registering tax invoices. Viktoria Kovalchuk is lead partner. 

Eterna Law commands extensive expertise in business taxation, including the tax structuring of transactions, international tax planning, VAT, customs duties and tax finance. The team regularly advises on tax structuring and determining the tax implications of various deals. In particular, it advised QTI Services in a M&A transaction, structuring international trade and loan transactions, including intra-group operations. The firm advised Omega, the largest operator on the Ukrainian market of automotive components, with tax diagnostics and strategic tax review of its corporate structure. The substantial workload of the tax practice consisted of newly-adopted CFC rules in Ukraine, interpretation and application of double tax treaties in light of the BEPS Multilateral Instrument, advising on “tax free liquidation” of foreign controlled companies (capital amnesty) and associated risks, structuring cross-border trade, including with the use of foreign jurisdictions, assessment of their tax implications and risks. Selected clients include Ukrgasbank, MDC Expert, Korolivskyi Smak, Ukrenergo, Ukrainian Tennis Federation, Ukrainian Fencing Federation. Partner Oksana Kneychuk splits her time between tax advisory and employment practices. 

EUCON Legal Group possesses a versatile tax practice with the growing number of complex cross-border tax structuring projects, tax disputes and its renowned strength – transfer pricing. The group has two offices in Kyiv and Warsaw, and commands a portfolio of outbound investment projects and tax structuring of supply chains. The team gave advice to Alumeta Trading, a company involved in the production and sale of alumina profile, tax consequences of supply chains from Ukraine to Poland and the EU; advised on the tax ramifications of buying out a stake in Plastics Ukraine from its founder – a resident of Poland. The firm represented Electrum Ukraine in a tax dispute in an administrative appeal of the decision of the tax authority not to refund VAT totaling USD 1.6 million; represented Cersanit-Invest in a tax dispute appealing against tax charges in corporate profit tax. The firm is well-known for its commitment to transfer pricing, and has a standalone practice that is a member of TPA Global. The dedicated TP practice group is sought after by established clientele (among others, Dreyfus Commodities Ukraine Ltd, Pruszynski Ukraine, PE SOLO Company, S Pharma, LLC, Zavod Kobzarenka, Magref LLC, Heraeus Electro-Nite, Plastics Ukraine) to develop their TP strategy and preparation of documentation. Larysa Vrublevska and Yuriy Chebotar are the leading names in the transfer pricing group. Andrii Romanchuk, head of the Warsaw office, advised Ukrainian and CEE companies on tax planning and international tax structuring. Yaroslav Romanchuk, managing partner, maintains strong practice guidance and a strategic role in client relationships.

EQUITY is one of the strongest litigation law firms in Ukraine, being a point of consistent choice for tax disputes. The firm represents the major industrial majors appealing against decisions of the tax authorities. The tax practice team continued representing the interests of the Azovmash Group of companies in tax disputes, including a dispute over VAT and the registration of a VAT tax credit; representation of the Insurance Company Avtoeksimbank in a dispute over the abolition of a tax notification-decision; advised PJSC UkrInCom on the legal tax consequences of changing its status by transferring the company’s loan portfolio. Partner Serhiy Chuyev is in charge of the tax litigation workload.

Housing one of the largest tax practices in two offices based in Kyiv and Lviv, EY Ukraine is preferred by global corporations and leading Ukrainian businesses as well as government and its authorities. The firm is hired for handling tax structuring, transaction support, regulatory, tax compliance, as well as development of Ukrainian tax policy. The firm is on the front of PSA projects in the Ukrainian energy sector, and conducted tax support of a production-sharing agreement for Aspect Energy. The EY team has been engaged in various projects anticipating technical support to Ukrainian Government authorities in the area of CRS/FATCA-, BEPS- and Diia City-related initiatives, including participation in developing legislative proposals. The team assisted the Ministry of Digital Transformation of Ukraine with developing and fine tuning the draft law governing the Diia City tax regime for its second reading in Parliament. Clients come from energy (especially oil and gas), IP/IT, manufacturing, maritime services, telecommunications, media, FMCG and financial services. The big practice team is led by partners Vladimir Kotenko, Igor Chufarov, Olga Gorbanovskaya and associated partners – Iryna Kalyta and Halyna Khomenko. 

Ukrainian law firm GOLAW is a reputed counsel with a long-term commitment to tax law, especially a strong track record of tax litigation, as well international tax planning and advisory. The firm advised the Export Guarantee and Insurance Corporation (EGAP) on the tax consequences of selling a united property complex to a non-resident of Ukraine (Swiss company) and the process of paying withholding tax; advised UkrCredit Finance on the tax risks and consequences of concluding a license agreement with a non-resident of Ukraine for using software. The team is skilled in industry specifics in such sectors as pharmaceuticals and healthcare, retail, FMCG, IT, publishing, education and private clients. The team represented Merkator Medical in the course of a judicial appeal against tax notice-decisions issued as a result is of an unscheduled tax audit by which the amount of VAT refund from the state budget was reduced. Tax partner Iryna Kalnytska is especially known as a strong tax litigator. Valentyn Gvozdiy, the firm’s managing partner, has a recognized legacy as a tax practitioner. 

Long-standing market player Gramatskiy & Partners predominantly advises domestic companies developing tax efficient investment strategies, cross-border trade, operation activity, assistance during tax inspections and tax disputes. The firm is known for its strong positions in the field of real estate, construction and development, often providing tax advice within supported construction and lease projects, as well regulatory work, including paying rent and land tax. Another substantial area of practice is giving assistance to IT companies, including tax structuring and tax regulation of Diia Citi project. This past year the firm advised on a tax amnesty initiative, as well as the restructuring of cross-border supply. The firm traditionally acts for its clients in tax controversies and supports respective inspections carried out by regulatory bodies. Clients include Seven Hills, Alfa Capital Invest, Promkabel-Elekrika, KSTT Services, Skywind Tech UA, PTS UA Services, Danfoss TOV, Sunrise Agro LLC, and others. Vitalii Tymchuk is the practice head.

Ukrainian tax boutique ID Legal Group predominantly represents domestic clients in the course of tax inspections, tax disputes, criminal matters evolving from tax evasion, and also assists with transfer pricing matters. On the tax advisory front, the team handled tax and legal analysis in the course of construction of wind and solar power stations, structuring of tax burden and risks in the project. In addition, the firm develops its transfer pricing practice, assisting clients with risk analysis and preparation of TP documentation. The main point of contact are partners Oleg Dobrovolskyi and Anna Ignatenko.

Ukrainian dispute resolution powerhouse Ilyashev & Partners has an established client bench consisting of major industrial leaders. The firm is sought after for representation in large stake tax and customs disputes, corporate tax advisory and international taxation. The team represented Poltava Petroleum Company in a series of disputes; in particular, recovery of tax debt from rent payment, and cancelation of tax assessment notices and drafting a complaint to the European Court of Human Rights to appeal decisions of the national courts on additional rent payment charges; acted for Feodosiya Shipbuilding Company More on restoration of the right to VAT credit and VAT refund for the period of 2017-2020. Clients include COFCO AgriUkraine, State Enterprise ANTONOV, Ferrexpo Belanovo Mining, Lundbeck Export A/S, Myronivsky Hliboproduct. The tax practice team is led by Roman Marchenko and includes Ivan Maryniuk and Dmytro Lazebnyi. Vitali Galitskih, the head of the Tallinn office in Estonia, who is responsible for international tax planning.

INTEGRITES has a notable tax practice team advising on a wide spectrum of client instructions, inter alia, general corporate tax advisory and industry specific tax issues, tax efficient structuring of investment projects, transactional tax, corporate restructuring, tax ramifications of changing business models. In addition, the firm is constantly chosen for representation in large-scale tax disputes. The firm traditionally supports projects in the renewable energy sector, also advising clients from healthcare, agriculture, IT and technology, steel and mining, financial services and fintech. INTEGRITES advised Epiroc Ukraine, a leading developer and producer of innovative drill rigs, rock excavation and construction equipment, on tax and customs issues related to day-to-day operations. Transfer pricing is a recent growth area. Viktoriya Fomenko, partner, head of tax and customs practice, is highly visible on the market.

After the amalgamation with the Kyiv office of DLA Piper in June 2021, Kinstellar obtained a very well-positioned tax practice with strong capacity in international tax, transfer pricing, tax controversies. Given the extensive portfolio of cross-border M&A, restructurings and other corporate deals, the firm ensures seamless tax advice of transactions and handled the tax structuring of the operations of clients in Ukraine. In particular, the firm rendered tax advice to 4i Capital Partners, a leading Ukrainian-based private equity firm, on the sale of its controlling stake in the Ukrainian online payment platform Portmone.com to Kaspi.kz, Kazakhstan’s largest financial technology firm; rendered tax advice to Vista, a Cimpress company, the world leader in mass customization, on its acquisition of the online graphic design editor Crello and a stock photo marketplace called Depositphoto. The tax practice is led by partner Illya Sverdlov, with contributions from Maryna Shulyk and Lyudmyla Dzhurylyuk.

KM Partners, a stellar Ukrainian law firm with a full-cycle tax practice as a recognized strength, retains an enviable client roster out of sound multinationals and sound domestic taxpayers. The firm provides comprehensive tax advisory, tax and customs litigation and subsequent white-collar crime, transfer pricing. The firm is particularly known for its extensive track dispute caseload, in 2021 having acted in several disputes between taxpayers and the tax authorities related to illegally imposed penalties for late registration of VAT invoices; challenging issues regarding CPT, including issues of advance payments; VAT refund, etc. Complex tax structuring is another area of the firm’s strong expertise. The team advised one of the largest producers of household cleaning supplies on the specifics of VAT taxation of transactions on supply of disinfectants during COVID-19 quarantine; conducted due diligence of an IT company (object of purchase), including analysis of existing employment relations as well as civil relations with entrepreneurs, revealing and assessing of the legal and tax risks of the business model. The big team is led by partners Alexander Shemiatkin, Ivan Shynkarenko, Elena Bukuyeva and Inna Taptunova. Senior partner Alexander Minin is a versatile and most reputable tax practitioner in Ukraine.

With two offices in Kyiv and Lviv, KPMG Law provides a well-versed tax offering encompassing domestic and international tax advisory, M&A tax support, tax compliance, tax litigation and standalone transfer pricing and private wealth practices. Over the last couple of years, the team was highly visible on the M&A scene, acting on the buy-side and vendor tax due diligence, as well as assisting with deal-related tax structuring. In a recent highlight the firm provided tax structuring advice to Calik Enerji Sanayi ve Ticaret A.S. in respect of activities related to the implementation of a major infrastructure project in Ukraine, including offshore and offshore parts, involving a significant number of foreign companies in the project; provided advice to a contractual joint venture of three of the largest Japanese engineering consulting companies headed by Nippon Koei Co., Ltd. providing consulting services to PrJSC Kyivvodokanal with respect to renovation of the Bortnychi Sewage Treatment Plant funded by the government of Japan. The firm’s dispute resolution practice has a new head, Nataliia Musiienko, who replaced Larysa Antoshchuk (joined Asters), who is in charge of representing clients in key transfer pricing and tax disputes. Yaroslav Kotliar is the head of its formidable transfer pricing practice. Oksana Olekhova heads the tax advisory group; and Sergey Popov is the head of tax and legal; Maksym Zavalnyy is the head of tax M&A.

Legal and Economic Security (LES) is a domestic litigation force with significant performance in tax litigation. The firm assisted clients with tax inspections, appeal of decisions by the tax authorities on tax charges, their inspections and orders, assets arrest, non-registration of tax invoices, exclusion from the category of risky enterprises. The firm’s client list takes in Alians-Lohistyk LLC, Insurance company Ukrainian Financial Alliance, VF Retail (Vodafone Ukraine), Prodmarket Treid LLC. Serhiy Kolisnyk, managing partner, is the main point of contact.

LCF Law Group has strong litigation credentials, and is regularly called upon to handle full-scope tax and customs dispute resolution. The team also regularly undertakes tax structuring mandates often linked to corporate/M&A transactions. The recent portfolio of projects included structuring clients operating activities, international tax structuring of private assets, VAT refund, preparing transfer pricing documentation. Notably, the firm was active in the area of agribusiness, food industry, retail, energy, gambling, high net worth individuals. Andriy Reun is a tax partner. 

Legal Alliance Company is an industry-focused boutique, which provides an extensive offering for pharmaceutical, healthcare, pharmacy industries. The tax practice rendered advice on recent changes to the Tax Code of Ukraine and the procedure for tax registration of a non-resident entity in accordance with updated tax legislation; provided an audit of current marketing agreements with pharmacy chains regarding their compliance with current tax legislation; provided tax risk analysis of relationships with contractors. Another area of services is tax disputes. Vitalii Savchuk, associated partner, heads the practice.

Lexwell & Partners has an impressive dispute resolution track record, and stands out in particular for representing major industrial leaders in high value tax litigation. The firm represents ArcelorMittal Kryvyi Rih in an administrative court and court of appeal on tax charges, and proved the groundlessness of claims against typical operations of the client; appealed against the results of a tax inspection on rent payment for the amount of USD 103.7 million. The firm also successfully represented Mykolaivcement, part of CRH Group, in the course of appealing against a number of decisions with additional tax charges. Andriy Kolupaev and Igor Nagai are the main figures.

The tax practice of MK Legal Service specializes in tax dispute resolution both in courts and through administrative procedures. Among the key cases in 2021 was successful defense of a state-owned enterprise as part of the Concern Ukroboronprom connected with the recovery of about USD 4 million in net profit; protection of numerous agricultural enterprises on VAT supplement disputes in administrative courts. Recent areas of growth took in an administrative appeal against refusal to register tax invoices. The tax practice is headed by associate partner Oleksandr Boyaryntsev.

MORIS has an extensive track record of tax disputes and substantial practice of tax advisory projects, in particular, tax and corporate structuring, including foreign jurisdictions, tax residence and planning. The team is particularly well-versed in appealing against the tax charges of excise tax and fines, handling representation of alcohol beverages and drinks producers in tax disputes. For example, long-standing client PBK Radomyshl PJSC in appealing tax notification-decisions on charges of excise tax liabilities after an unscheduled tax inspection; levying of fines in violation of turnover of excisable goods, charged penalties for violation of time periods for foreign currency payments with non-residents; cancellation of penalties for the unlawful alienation of property under a tax lien. The lead partner is Vasyl Andrusyak.

Ukrainian law firm NOBLES provides tax advice within comprehensive legal support of investments into Ukraine, commercial transaction structuring, currency control compliance, debt assignment and settlement, profit and investment repatriation, import/export relations, sophisticated cross-border payments, etc. The firm provides comprehensive legal advice to Beam Suntory, one of the largest producers of distilled beverages worldwide on a wide range of complex legal issues, including permanent establishment, the newly-introduced tax registration of a parent company in Ukraine; tax aspects of employee incentive schemes; acted for Llentab Ukraine LLC, the subsidiary of a leading Swedish steel constructions manufacturer, on contractual VAT issues. The firm advised investors of the new, first Canadian bilingual school in Ukraine, under the franchise of the global Maple Bear network, school on Ukrainian legal and tax matters, including direct and indirect tax advice on key operations of the school, financing and profit repatriation, real estate lease, structuring relations with the clients and owner of the franchise, application of the “beneficial owner” tax concept to franchise fees. Among the firm’s other clients are Ivoclar Vivadent AG, Ivoclar, H&M Hennes & Mauritz, Auto1. Alexander Weigelt and Volodymyr Yakubovskyy are lead partners.

The Ukrainian office of Peterka & Partners provides its clients with tax advice at various stages of their activities in Ukraine: from initial advice related to setting up a legal presence in Ukraine to complex support of fully-fledged activity. The team provided 3Dees Industries s.r.o. with complex tax assistance related to entering the Ukrainian market; provided comprehensive tax advisory to Atlas Copco, a significant international industrial group, on intra-group restructuring involving a Ukrainian subsidiary; World Courier and its Ukrainian subsidiary with the tax advisory on matters of structuring local supply chains. Mammoet, the Ukrainian subsidiary of a world-leading company specializing in engineered heavy lifting and transportation of oversized and heavy objects, enlisted the office for representation in a court dispute regarding the annulment of a tax ruling, assistance in a customs issue stemming from the ongoing challenging of additional VAT accrual in court, advising on double taxation matters, permanent establishment risks under outstaffing models, tax and other regulatory aspects of transferring title to  equipment, etc. Galyna Melnyk, deputy director for the Ukrainian office, is the practice head. Tatiana Bagmet and Klara Karapetian are other key members of the team. 

Redcliffe Partners advises on general and strategic tax issues and covers the tax aspects of corporate transactions. The tax practice advised Concorde Capital on tax issues arising from the privatization of the President Hotel in Kyiv; advises Eni on all issues arising from the company’s activity in Ukraine, particularly tax matters related to the implementation of oil and gas projects. The client roster includes Engelhart Commodities Trading Partners, British American Tobacco Ukraine, CMA CGM Ukraine, MNG Group of Companies, United Farmers Holding Company, J.P. Morgan, EBRD, Representative Office of EIB, Cargill, Allseeds Group and others. Tax head Oleksandr Markov was promoted to partner.

Sayenko Kharenko has a formidable highly-reputed tax team with a broad offering for multinational and domestic corporate advising on the tax aspects of transactions, general corporate tax advisory, transfer pricing, and handling tax controversy and litigation matters. In a recent highlight, the firm rendered transactional tax advice to Creatio on raising investment from private equity funds; vendor tax assistance to Bel Group on the divestment of a Ukrainian business; acted as a “one-stop shop” legal advisor to the global top-tier gaming company Yolo Group in connection with it entering the Ukrainian market. The team is highly visible on the tax litigation front, being instructed for representation in resonant tax disputes. In particular, the practice team represents the companies of the Agromino group in several tax disputes relating to, inter alia, VAT matters and the registration of the taxpayer on special conditions within the simplified tax regime (agricultural producers); represents Philip Morris Ukraine in several tax disputes with a local tax authority regarding tax assessments related to excise tax, corporate profit tax and VAT. Notably, the firm continues to develop its TP practice, including TP disputes. The practice has two partners on board – Svitlana Musienko renowned for international tax planning experience; and the recently promoted Vitaliy Odzhykovskyy who is in charge of tax litigation. Dmytro Korbut, counsel, is another key team figure. 

Long-standing market player Sokolovskyi & Partners has its tax practice among core offerings and commands an established track record of disputes with tax and customs authorities by challenging their inspections and orders, assets arrest, non-registration of tax invoices, appealing against the actions of tax management officers, etc. In addition, the team works closely with the criminal defense team on tax evasion cases. This past year the practice team expanded its tax advisory volume with queries on international tax structuring and risk analysis. The team advised Geozem Makariv LLC on the taxation of an agrarian company and its export operations; developed tax structuring for Altacore Holding, an ІТ company with 70 IT developers; assisted Merynos with reorganization of farming manufacturing business. The firm’s client roster includes Pelagia Ukraine, Egerzund Seafood, NSI Bud, Sentiss Pharma, Solar K, Agricom Group, Avtozvuk. The firm’s partners Natalia Kurilenko and Vladyslav Sokolovskyi are widely known tax practitioners. Tetiana Lysovets is in charge of representation in criminal proceedings on alleged tax invasion.

Having clients from the IT and technology sectors, Ukrainian firm Stron Legal Services is known for handling extensive experience in international tax structuring. The firm acts for corporate and tax structuring of e-commerce and fintech businesses in the EU and Asian countries; providing established tax planning services to the gaming sector; tax structuring of holding companies and compliance issues. The team has also registered a client’s companies in the system of simplified VAT payment for electronic and digital services in the EU. Oleg Derlyuk, managing partner, is the main contact. 

As a boutique focused on white collar crime, dispute resolution and investigations, VB PARTNERS has a consistent commitment to large stake tax disputes often accompanied by criminal proceedings with regard to tax evasion. The firm represents huge industrial clients in appealing against additional charges of tax liabilities, VAT refunds from the state budget, fines for delays in registration of tax notes, etc. For example, the firm represented the interests of the distributor of the only producer of primary aluminum in Ukraine in a lawsuit on entering data into the VAT register and recovering a penalty from the state budget; acted for the largest representative of the electrical equipment segment, in the administrative appeal of tax notices-decisions. Notably, the firm represented Goldfish-Invest-Bud, a leading development company, in appealing against the additional accrual of tax liabilities in the amount of USD 40 million for the benefit of the owner of one of the largest office centers in Ukraine. Other clients include shareholders of Commercial Bank Premium, Delta Bank, Svitland Development, Colliers International, Immer Group, Allo, Global Maritime Consultants Group, Lascos Ukraine, Volt Engineering, Real Group, etc. Partner Vladimir Vashchenko is in charge of tax litigation. 

Vdovychen & Partners represented clients in disputes appealing against notifications-decisions, renders support during tax inspections, and tax structuring assignments in the course of business model development and corporate reorganizations. This past year the firm advised on a tax amnesty legislative initiative in Ukraine; handled the tax structuring of an IT co-working business; conducted an audit of business models of shoe manufacturing on the tax risks. Oleg Vdovychen and Andriy Molchanov are responsible partners. 

Wolf Theiss, with its extensive CEE network of offices, assists international business entering the markets. The Kyiv team supports clients with tax structuring at the time of entry into the country, tax structuring of transactions, operations and investments, including outbound investments by Ukrainian businesses. A substantial share of work was generated by IT and technology companies. The firm advised Apalon, an IT product company headquartered in the US, on various tax matters in connection with the relocation of its IT business from Belarus to Ukraine, including with respect to CIT, VAT and the taxation of employees and individual contractors; advised Microsoft Corporation, an American multinational technology company which produces computer software, consumer electronics, personal computers, and related services on various corporate tax matters in connection with its products warranty program. Furthermore, the team acted for Ukrmilk on structuring and carrying out a dairy project across Ukraine. Clients encompass Federal-Mogul Motorparts, Nvidia Corporation, Optimum Solar Kft, Snap Inc., Remington Seeds, Avaya Netherlands B.V., Gaas Holdings, Urban Leap Inc. The main contact is Taras Dumych, managing partner.

Regional Counsel 

Odesa-based law firm Jurline has an extensive client roster consisting of major industrial and port infrastructure leaders. The team possesses a solid tax advisory offering, as a part of comprehensive business project solutions, tax specific advice, as well as representation in tax controversies. Jurline represents the interests of the winery PJSC Odesavinprom, a well-known Ukrainian manufacturer of wines and sparkling drinks, in the course of it challenging additional charges and adjustments of additional income tax liabilities and VAT. The firm has acquired experience of transfer pricing disputes, and most recently represented the interests of TIS Grain terminal and TIS-Mindobryva terminal, part of TIS group, in the port of Yuzhny in challenging a tax notice-decision to which the company was additionally charged with additional income tax liabilities in connection with alleged non-compliance with transfer pricing rules. Vitaliy Cherkes, Maxim Kapelist and Daria Minchenko, who was promoted to partner in autumn 2021, are the key figures.

Krolevetskyi & Partners, a domestic Kharkiv-based law firm, possesses expertise in transactional tax issues, including transactions with property and corporate rights, general advisory on corporate taxation. In addition, the firm renders support with tax inspections and representation in respective disputes with the tax authorities. The firm represented the State Enterprise Kharkiv Plant of Armored Tanks in litigation appealing against the result of tax audit and additional charges and penalties. Other clients include Stalconstructia Ltd and LLC Recycling Group. The practice head is Ruslana Pyvovarova.

Legrant, an Odesa-based law firm, is a popular choice for major exporters, traders, stevedore companies. This past year the firm was active in tax litigation, being particularly well-versed in tax controversies arising out of foreign economic contracts and netting between counterparties, additional VAT and corporate profit tax charges, proving the reality of business transactions. Tatiana Titarenko is the main contact.

The Kharkiv-based law firm Shkrebets & Partners is known for its extensive caseload of tax disputes. The firm is consistently preferred by major regional industrial clients, and by state and municipal enterprises. The track record traditionally encompasses challenging tax liabilities and the blocking of tax invoices, as well criminal proceedings on tax evasion. Clients include PJSC Kharkiv CHP-5, Kharkiv Heating Networks, and a number of municipal enterprises. Evgeniy Shkrebets and Yuriy Artukh are the lead partners.


[1] Myroslava Savchuk, who was focused on tax litigation, left to become head of legal at DTEK Renewables.