Asters disposes a full-scope tax practice advising clients on tax structuring (e.g., within corporate reorganization, mergers and acquisitions, etc.), including outbound investment, and representation in tax disputes. The team has a wide range of prestigious international and domestic clients, assigning the team for complex multijurisdictional mandates. Over the recent two years, the tax team has provided specialized advisory services across key sectors including oil and gas, pharmaceuticals, public contracts and infrastructure, mobile telecom payments, e-sports and gambling, handled wealth management for high-net-worth individuals, and tax structuring for non-profit organizations involved in national educational projects. The tax team assisted FC Shakhtar, the well-known Ukrainian football club, in optimizing the tax structure for their agreement with a German football club regarding the distribution of profits from UEFA Champions League home matches. In the research period the firm assisted a group of Ukrainian and foreign businessmen with declaring in Ukraine their annual income in the amount of USD 28.7 million received abroad and paying USD 5.6 million in taxes to the state budget of Ukraine. The well-established track record of tax disputes features with complex cases. The team recently successfully represented LLC UKRPANGROUP (Arricano Group) in a tax dispute over discounting liabilities and fair value assessment of investment properties; represented West Gate Logistic LLC in a dispute over improperly applied discounting calculations on loan agreements, where the appeal court overturned the initial tax notification-decision due to illegal tax audits in 2021, with subsequent cassation appeals by the tax authority returned as unsubstantiated. Constantin Solyar is lead partner and head of the tax practice. The key team members of the consulting team include Yurii Dmytrenko, Roman Podzizei, and Pavlo Shovak. Larysa Antoshchuk, recognized as being among the strongest tax litigators, fronts tax disputes. Oleksandr Matokhniuk makes an important contribution to the disputes team.

The Kyiv office of Baker McKenzie specializes in sophisticated international and domestic tax planning, supporting major corporations with tax structuring for inbound and outbound investments, M&A, and corporate restructuring. The offering extends to VAT planning and litigation, global wealth management for private banking and families, fringe benefits and retirement tax planning, customs compliance and litigation. The tax team continued advising the shareholders of Biopharma, a leading Ukrainian manufacturer of pharmaceuticals and healthcare products, on the tax implications of the carve-out of its non-plasma business and its further sale to Stada AG. During the research period the tax team delivered advice on tax and legal ramifications in relation to business models operating in Ukraine, including on the challenges posed by wartime and martial law limitations; advised on introduction of Anti-BEPS provisions into domestic legislation. Having a strong following among IT companies, the firm advised on the Diia City regime. The firm also offers comprehensive transfer pricing services, including compliance, documentation, and audit support. Hennadiy Voytsitskyi, tax partner, specializes in advising multinational and domestic clients on international tax planning and tax structuring. The key team member is senior associate Roman Koren.

EUCON Legal Group is known for its comprehensive tax practice, which includes tax structuring and planning, international tax, tax litigation, and transfer pricing. The group operates from two offices located in Kyiv and Warsaw, offering specialized advice on tax implications related to business and employee relocations, changes in supply chains, Ukrainian companies entering the EU market (particularly Poland), corporate reorganization, and the effects of martial law. During the research period the firm advised business owners in Ukraine and the EU on registration of foreign companies with the State Tax Service of Ukraine, determining the status of a tax resident, application of legislation on controlled foreign companies, etc. In particular, the team advised the Ukrainian travel operator JoinUP on taxation issues related to determining its tax residency status and taxation following the relocation of the company’s employees to Poland; advised Hitachi Energy Ukraine on the taxation of the supply chain of transformers manufactured in Poland to Ukraine. The firm is known for handling complex large-scale tax disputes. Among the notable recent highlights was representing Electrum Ukraine in a tax dispute regarding the appeal of a tax notice-decision denying a VAT refund; acts for Cersanit-Invest, a Polish company specializing in the production of ceramic tiles and sanitary ware, in a tax dispute regarding the appeal of tax notices on decisions to impose income tax liabilities, and on VAT in respect of software development and support services for the total amount of USD 14.9 million; supports Agroterra LLC, the official dealer of the world’s leading manufacturers of agricultural machinery, in a tax dispute regarding a judicial appeal against inaction on the part of the State Tax Service and provided legal support in appealing against the illegal reduction in the VAT registration limit. The robust transfer pricing team advised a number of clients, among others, Dreyfus Commodities Ukraine Ltd, Pruszynski Ukraine, Plastics Ukraine, Biolabs, LLC, Ukrainian Grain Logistics, LLC, Ukrainian Elevator Company, LLC. Andrii Romanchuk, who heads the Warsaw office, provides tax planning and international tax structuring advice to Ukrainian and CEE companies. Yaroslav Romanchuk, the managing partner, offers strong practice guidance and plays a strategic role for the firm. Vitaly Kemin, senior associate, is noticeable in tax disputes. Larysa Vrublevska and Yuriy Chebotar lead the transfer pricing group.

EY Ukraine’s extensive practice is favored by international corporations, top Ukrainian companies, government bodies, and business associations for managing tax structuring, transactional support, regulatory compliance, and Ukrainian tax policy development. In addition, EY offers advice to government bodies and business associations on significant tax matters. Given the firm’s robust M&A workload throughout the research period, EY ensured tax advice within supported transactions. Expertise in the industry spans energy (particularly oil and gas), IP/IT, manufacturing, maritime services, telecommunications, media, FMCG, and financial services. The team continued to be engaged in projects, providing technical support to Ukrainian Governmental authorities on initiatives related to CRS/FATCA, BEPS, and Diia City, including involvement in the development of legislative proposals. In particular, the team provides on-call assistance to Tetra Tech ES in implementation of the Energy Security Project as part of international technical assistance. Throughout 2022-2023, the Kyiv office actively assisted clients in navigating the complexities posed by wartime conditions. EY boasts a formidable transfer pricing practice with a comprehensive range of services. The extensive practice team is headed by partners Vladimir Kotenko, Igor Chufarov, and Olga Gorbanovskaya, alongside associate partners Iryna Kalyta and Halyna Khomenko.

KM Partners, a prominent Ukrainian law firm, is celebrated for its comprehensive tax practice that caters to a prestigious clientele, and offers extensive services in tax advisory, tax and customs litigation, white-collar crime defense, and transfer pricing. On the advisory front, the firm was called upon to handle tax due diligence of clients’ activities, give assistance in the planning and structuring of business activities from a tax and customs perspective, issues related to application of double taxation treaties, etc. The firm has built a robust reputation in managing tax disputes, particularly for clients in the agro-industrial sector. For example, the firm successfully defended an agro-industrial company that exports grain and works in the field of port infrastructure on its right to nearly UAH 2.5 million in VAT reimbursement from an illegal tax audit that delayed and denied payments exceeding UAH 11.5 million. KM Partners represented auto and property insurance company successfully challenged the tax authority’s claim that having two agents for one insurance contract was unrealistic, proving such a practice is legally permissible and economically sensible for the company’s business model. The firm’s offering traditionally cover transfer pricing, handling TP analysis, developing and implementing TP policy, defense in TP disputes with the tax authorities headed by partner Ivan Shynkarenko. Alexander Shemiatkin and Elena Bukuyeva are known for experience in tax disputes. Inna Taptunova advises on a wide spectrum of tax consulting matters. Senior partner Alexander Minin is recognized as one of the most distinguished and versatile tax practitioners in Ukraine.

KPMG Law traditionally offers a comprehensive tax service that includes domestic and international tax advisory, support for tax aspects of corporate deals, tax compliance, tax litigation, as well as transfer pricing. The firm is called upon to give tax advice for structuring of operating activities in Ukraine and internationally. During the research period the firm represented a local branch of a multinational home appliances manufacturer in challenging tax notices at both pre-trial and trial stages, following a scheduled tax audit that accused the client of various tax violations including fictitious transactions and reporting errors; defending Canon Ukraine in a tax dispute following an unscheduled audit regarding FY2015-2016 on controlled transactions’ compliance with the arm’s length principle; represents Viva Décor LLC in a landmark litigation case challenging the results of a transfer pricing tax audit. ProCredit Bank engaged the firm to assist with implementation of the Common Reporting Standard (CRS) in Ukraine. Being a prominent provider of TP services, the dedicated team acts for a broad variety of clients. Oleksandr Boboshko and Oksana Olekhova are at the forefront of tax consulting; Iryna Khyliak became head of tax audit and disputes. Yaroslav Kotliar heads the transfer pricing practice. Sergiy Popov is head of tax and legal.

Throughout the research period the tax practice workload of Sayenko Kharenko encompassed transactional tax structuring for large cross-border transactions, general corporate tax advisory, in particular, tax issues related to reorganization of international groups of companies, and sizeable caseload of tax litigation, including criminal proceedings concerning alleged tax evasion. Among public disputes was representing the companies of Agromino group in several tax disputes relating to, inter alia, value-added tax matters with a total value of about USD 4.6 million, and the registration of the taxpayer on special conditions within the simplified tax regime (agricultural producers); representing Reckitt Benckiser Household and Healthcare in several tax disputes regarding the refusal to refund VAT for imported goods; representing Samsung in a tax dispute regarding VAT assessments on transactions related to writing-off of fixed assets and product samples. It is noteworthy that the firm was enlisted for assessing possible changes of tax residency for employees of various clients in connection with forced displacement of employees overseas due to armed aggression by Russia. Among the highlights of transfer pricing advice was assistance with the application for the mutual agreement procedure (MAP) regarding transfer pricing adjustments and respective tax assessment made by Ukraine that were not compatible with the Ukraine/Swiss double taxation treaty; representation in a tax dispute that relates to transfer pricing audit issues with the state tax authority. Tax partner Vitaliy Odzhykovskyy is known as an efficient litigator. Senior associate Kateryna Utiralova is an important team member. The tax planning within the framework of inheritance and private wealth planning, as well as tax structuring of foreign transactions is run by the firm’s wealth partner, Alina Plushch.[1]

MORIS boasts a robust history in tax dispute resolution and a well-established tax advisory practice, specializing in tax and corporate structuring across national and international landscapes, including issues of tax residence and strategic tax planning. The firm excels in national and international tax consulting, tax litigation, comprehensive business restructuring, currency legislation, transfer pricing, and customs law. The tax practice also advises IFCEM, a major Ukrainian cement and concrete industry player with holdings in Switzerland, Cyprus, and Slovenia on the tax implications of new 2022 legislation on controlled foreign companies; advised IF-Gips to establish a new business in the gypsum mining industry, addressing complex tax planning and project financing amid Ukraine’s currency control restrictions due to ongoing war; continued to support Promprylad.Renovation, the largest and most innovative impact investment project in Ukraine, addressing diverse tax-related matters, including those pertaining to real estate, the contribution of intellectual property to the authorized capital of the company, and advising investors on the overall project structure. The dispute team represented Radomyshl and successfully challenge a tax notice-decision. The tax dispute team works alongside criminal practice in cases involving tax evasion, For instance, the firm acted for Tedis Ukraine, the biggest distributor of tobacco products in Ukraine, which is facing allegations of tax evasion totaling more than USD 8 million. Vasyl Andrusyak, partner, leads the tax practice.

Sokolovskyi & Partners, a well-established firm on the market, prominently features its tax practice as one of its core services. The firm boasts a strong history of successfully contesting the actions of tax and customs authorities, including challenging tax inspections, orders, asset arrests, and non-registration of tax invoices, exclusion from the category of risky companies. The tax team traditionally collaborates closely with the criminal defense team on cases related to tax evasion. In the research period the firm was assigned for advising on taxation during the martial law. The firm’s partners, Natalia Kurilenko and Vladyslav Sokolovskyi, are well-recognized tax practitioners. Tetiana Lysovets leads the representation in criminal proceedings regarding alleged tax evasion.

The tax practice of Dentons is called upon for strategic tax planning advice, support for business restructuring, tax compliance and transactions. The practice offers tailored advice across various sectors including IP and IT, natural resource production, agriculture, real estate, and provided crucial support to the humanitarian and NGO sectors. The multinational team provided TIU Canada with comprehensive legal support on exporting solar power plant equipment to Poland, including advice on Ukrainian, Polish, and Dutch legislation regarding intragroup debt restructuring, as well as tax, customs, and regulatory considerations; advised a Ukrainian energy and gas trading company on tax and corporate in connection with the acquisition of a cooperative and its further development and renovation; delivered litigation support for a Polish manufacturer in tax disputes; advised on general tax matters related to the establishment of a charity fund and LLCs to provide humanitarian aid in Ukraine. Among other notable engagements were advising on the taxation of stock option plans, taxation of royalty payable to foreign trademark owner, application of double taxation treaties to mitigate tax risks. The tax practice is led by partner Igor Davydenko, while Ihor Mehedynyuk provides tax advisory services to several major international clients. Valeria Tarasenko serves as a key tax advisor within the group.

Gramatskiy & Partners provides comprehensive tax services that include tax optimization, planning, and administration. They assist with resolving tax disputes, defending businesses during audits, managing controlled foreign companies, and handling transfer pricing. The firm excels in international tax planning and capital protection, helps with the acquisition and change of tax residency, and addresses the taxation of innovative industries such as Diia.City and gig contracts. The team also specializes in protecting individual entrepreneurs. The firm advises Danfoss TOV, LLC regarding the tax consequences of assets destruction – warehouse in hostilities; acted as legal counsel for SW UA, and conducted due diligence on software development service contracts in light of the expiring VAT exemption for software-related transactions, and consulted on the taxation of non-monetary dividends paid to non-residents under the Ukraine – Cyprus Double Taxation Treaty. Clients include Seven Hills, City Capital Group, Golden Mandarin, Promkabel-Elekrika, Sunrise Agro LLC, etc., among others. Vitalii Tymchuk is the practice head.

Ilyashev & Partners’ tax practice encompasses a stand-alone tax advisory service for specific issues, a formidable tax litigation arm dealing with high-value disputes, and corporate support tax practice. The tax team has become increasingly sought after for expertise in managing large and complex projects, particularly in tax controversy. Notably, the firm excels in challenging tax assessment notices, securing VAT credits and refunds, and appealing penalties. The Feodosiia Shipbuilding Company Morye was represented in a complex six-year long legal battle against tax authorities over additional taxes and duties amounting to USD 2 million across seven cases, where the firm successfully secured the majority of VAT refunds, despite initial setbacks and challenging circumstances including lost documents and jurisdictional changes following the annexation of Crimea by Russia. The team acts for Reikartz Hotel Management, a Ukrainian management company of the hotel chain operating under the umbrella brand Reikartz Hotel Group, appealing against tax notices-decisions and the annulment of a license for wholesale alcohol; represented Ukrrichflot, a private logistics operator and a shipping company with its own infrastructure, which provides integrated logistics solutions using the Dnipro River, successfully appealing tax notice-decisions. The firm advises AVSI Foundation, an international non-profit and non-governmental organization, and Terre des Hommes, the leading Swiss organization for children’s aid, on taxation of a charitable aid, the mechanism for determining tax liabilities and submission of reports; renders comprehensive tax and legal support to Ecolab, an American corporation, one of the world leaders in the chemical industry. In 2023, Ivan Maryniuk, who is focused on tax planning, was promoted to head of the tax practice. Kharkiv-based attorney Dmytro Lazebnyi was endorsed for his experience in tax litigation.

INTEGRITES is assigned for tax consulting, including that pertaining to martial law, tax controversy, transfer pricing and for giving advice to private clients on tax-related matters in tax disputes. The team is consistently enlisted by large industrial taxpayers for representation in tax disputes. Given the firm’s significant portfolio of renewable energy projects over the last couple years, the tax practice is engaged in advising tax and customs issues related to the development of relevant projects. For example, the firm has been providing ongoing tax and customs advisory services to Syvashenergoprom for the Syvash wind farm project, successfully challenging a controversial tax assessment levied by Ukrainian customs authorities during a 2021 audit; continues to navigate emerging tax and accounting issues in terms of martial law and the project’s occupation by Russian forces. The team acts for Gradoil Group in three tax disputes focusing on validating the legitimacy of transactions and the accuracy of tax report data, including changes to VAT obligations due to adjustments in the delivery and quantity of exported agricultural goods; represents Dunapack Packaging in a complex tax dispute over additional VAT, corporate profit tax, and fines stemming from early transfer pricing methods during their initial establishment in Ukraine (2012-2013). Transfer pricing advice is a growing practice offering. Partner Viktoriya Fomenko, who leads the tax and customs practice, effectively utilizes her expertise in both advisory and litigation capacities.

During 2022-2023, Kinstellar’s tax practice was called upon to provide international tax structuring for businesses undergoing relocation or restructuring, ensuring efficient transitions, and providing mergers and acquisitions advisory, structuring projects, and tax risk assessments. The team also supports non-organizations and NGOs, as these entities intensified their activities amid the war, and was deeply involved in international technical assistance projects. Furthermore, Kinstellar assisted IT companies adapt to the Diia.City regime, advising on compliance, tax benefits, etc. The office possesses legacy expertise in developing and implementing a practical transfer pricing policy, assisting companies follow these rules by advising on compliance and reviewing their transfer pricing policies and documents. Selected clients include Jabil Circuit, Pfizer, Maersk, NEQSOL. Senior associate Lyudmyla Dzhurylyuk, deputy head of banking and finance, is head of the tax practice. Illya Muchnyk, who is a partner in the Kyiv office, oversees the firm’s tax practice.[2]

PETERKA & PARTNERS offers tax and regulatory advisory services across all phases of business operations in Ukraine, business restructuring and corporate transactions, handling representation in tax disputes in courts. The firm tackles complex double-taxation issues under Ukrainian and international law, especially for Ukrainian expatriates, and provides extensive legal support to clients impacted by document destruction resulting from Russia’s war. During the research period the firm continuously provides comprehensive tax support to Polpharma regarding the wide range of contracts underlying the company’s business activities in Ukraine (such as distribution, storage, lease, promotion etc.) and practical advice on their performance; provided World Courier with complex legal support in mitigating adverse tax and regulatory consequences related to its primary documents being destroyed due to the war. On the litigation front the firm successfully represented Mammoet in court to annul an adverse tax ruling, providing comprehensive tax and procedural support concerning VAT on the re-export of equipment; represented the leading CEE mobile brand developer TCCM in a VAT dispute. Halyna Melnyk, deputy director for the Ukrainian office, was appointed a co-leader of the firm’s global tax desk. Klara Karapetian is the key member of the tax team.

Redcliffe Partners offers guidance on general and strategic tax issues, specializing in the tax aspects of corporate transactions, and is particularly skilled in oil and gas tax matters, including Production Sharing Agreements (PSAs). The firm also advises on tax issues related to project financing and profit repatriation. The firm provided Seven Energy with comprehensive legal and tax advice on storing natural gas at Ukrtransgaz’s facilities and its subsequent re-export to the EU, navigating the complex regulatory and tax challenges exacerbated by Russia’s ongoing war; advised Jakala S.p.A. S.B., the leading European independent private equity investment company, on the transaction in relation to acquisition of FFW, a Denmark-based company specializing in the marketing strategies; advises Eni on all issues arising from the company’s activities in Ukraine; renders ongoing advice to Yazaki’s Ukrainian business, etc. Albert Sych, partner and head of the corporate practice, took in the role of the tax practice’s lead partner.[3]

Stron Legal Services, a Ukrainian firm with a client base in the IT and technology sectors, possesses extensive experience in international tax structuring. During the research period, the firm’s portfolio included tax planning for a streaming platform specializing in e-commerce, structuring a group of companies and a holding entity across Malta and various EU countries, and similar structuring for groups in the EU and Asia. The team also provided tax guidance for a cryptocurrency company dealing with Virtual Financial Assets and e-commerce businesses that sell e-books and video content. The firm also offered strategic tax advice for a media buying holding. Oleg Derlyuk, managing partner, is the main contact.

ADER HABER, a Ukrainian law firm, is known for representation of clients in tax controversies in administrative order and courts. During 2022-2023, the firm represented a company belonging to a group of energy companies engaged in the repair and maintenance of industrial equipment in challenging the results of a tax audit, which had deemed transactions as fictitious and imposed income tax and VAT liabilities, successfully argued the audit’s illegality and the validity of the transactions. In another highlight the team successfully represented an investment company in a tax dispute to recognize a tax credit, which was later contested by the tax authorities in 2022 due to three separate invoices issued for a single payment; the firm filed a claim defending the invoices’ validity based on the transaction’s nature. The firm represents SE Starokostiantyniv Dairy Plant in five tax disputes – two disputes on appealing against tax surcharges and three interrelated disputes. The team also continues to further develop its transfer pricing expertise and, in particular, acts in the relevant disputes. For example, the firm represented a Ukrainian trader engaged in the export of grain crops, during a tax audit and subsequent legal disputes involving controlled transactions from 2013-2015, having challenged the assessments made by the tax authorities in court, resulting in the cancellation of disputed tax charges. Other disclosable clients include MHP, Colliers International LLC, PJSC Metlife, Inditex Ukraine LLC. Tatiana Daniltseva, partner, and Stanislav Karpov, counsel, co-heads the tax practice. Vadym Ponomarenko, attorney at law, is a key team member.

AMBER Law Company is renowned for its effective handling of tax disputes, particularly in restoring taxpayer status as VAT payers, removing taxpayers from incorrect “risky” classifications by tax authorities, challenging both the process and outcomes of tax audits that violate legislation, securing refunds of wrongly or overpaid taxes and fees. The firm successfully supported a big Ukrainian tobacco production wholesale company regarded as risky by the local tax service, which had refused to register their tax notes due to transactions carried out with risky companies. Another highlight includes representing a Ukrainian agricultural producer and agricultural production wholesale trader in an administrative tax dispute over several years, leading to the Supreme Court of Ukraine upholding the cancellation of an unlawful decision adopted by the tax authority against the client as a VAT payer, with ongoing efforts to recover funds debited from the client’s VAT account, now involving a new court case regarding non-compliance with the judgment. On the advisory front, the firm renders tax consulting and compliance service. The client roster encompasses agriculture, tobacco, healthcare, investment, wholesale trade. Andrii Valenko and Katerina Drobyazko are important members of the team. Semen Khanin, the firm’s managing partner, guides the tax practice.

As a strong litigation market force EQUITY is consistently chosen for its expertise in handling tax disputes. The team deals with a variety of issues, including blocking tax invoices and their registration, the exclusion of a taxpayer from the list of taxpayers meeting risk criteria, application of double taxation treaties. The firm advises the Azovmash group of companies in a tax dispute regarding the accrual of tax debt by the State Tax Service of Ukraine, consisting of corporate income tax, excise tax, value added tax and the unified social tax to entities located in occupied territories. The firm advised PJSC UkrInCom (PJSC UkrInBank) on the legal tax consequences of changing its status and transferring the company’s loan portfolio. Serhiy Chuyev, partner, is in charge of the tax litigation workload. 

ID Legal Group, a Ukrainian tax boutique, primarily assists domestic clients with tax inspections, disputes, criminal cases related to tax evasion, and transfer pricing issues. Since Russia’s full-scale invasion the firm has been addressed with a range of specific matters, among others, resumption, suspension and termination of operations, martial law reporting, relocation of enterprises from the war zone, accounting of mobilized employees, transition to a different taxation system, employment conditions for internally displaced persons. The workload included resumption of the company’s operations after it was classified as a risky business, support for the State Tax Service’s audit, representing firms in appealing against tax notices. The transfer pricing practice includes consulting and support at the stage of business transactions that are recognized as controlled, assistance in identifying controlled transactions, preparation of reports and documentation on controlled transactions for fiscal authorities, risk analysis, formulation of recommendations, etc. Partners Oleg Dobrovolskyi and Anna Ignatenko are the main points of contact.

LCF Law Group is well-regarded for its robust litigation expertise and is frequently sought after to manage comprehensive tax disputes. The team frequently handles tax structuring tasks for businesses and international tax structuring of private assets, tax structuring of payment of dividends, taxation of assets transfer, advising the client on issues regarding CFC (controlled foreign company) reporting. The firm’s clients come from agribusiness, food industry, retail, energy, gambling. Tax partner Andriy Reun is noted for his activities in the professional community.

Lexwell & Partners is distinguished for its outstanding dispute resolution capabilities, particularly noted for representing leading industrial clients in high-stakes tax litigation. In particular, the firm successfully represented ArcelorMittal, Ukraine’s largest mining and metallurgical producer, in a series of inter-related litigations against the tax authorities involving disputes totaling over USD 100 million. On the advisory front, the firm advised an Austrian-based company called Euroventures to ensure tax-efficient approach with regard to the ownership structure and operational mode of the business/office center in Kyiv; advised CRH Group, Ukraine’s largest cement producer, on tax matters related to its acquisition of cement, ready-mix concrete, and logistics businesses from Buzzi (Dyckerhoff Group) in Ukraine. The main contacts are Andriy Kolupaev and Igor Nagai.

VB PARTNERS maintains a continuous focus on tax disputes that are accompanied by criminal proceedings with regard to tax evasion. Among the highlights of the research period were representing a key shareholder and top management of Delta Bank in a criminal tax evasion case, where the court denied a motion to extend the investigation period in October 2022, highlighting procedural irregularities by the prosecution; representing the interests of a real estate company called Real Group in a legal dispute on granting permission to the tax authority to sell non-residential buildings. The firm is representing Svitland Development in a criminal case on the alleged evasion of UAH 8.3 million in land tax from 2017-2019, focusing on the absence of an agreed tax notification-judgment to demonstrate the proceedings’ futility and the illegality of tax decisions. The firm’s public clients include shareholders and top managers of Sense Bank, Premium Bank, Tascombank, SNEL Energy, Svitland Development, Ukrainian Association of Football and its subsidiaries, Colliers International, Q Partners, TAS Group, Helios Financial Corporation, etc. Volodymyr Vashchenko is the lead partner. 

Vdovychen & Partners advises on tax risks and compliance, and traditionally represent clients in disputes appealing against notifications-decisions. During the research period, the team conducted legal due diligence on business transactions and relationships to assess tax risks, ensured compliance in gig contracts, advised on the tax implications of marketing operations, and provided guidance on transfer pricing with non-residents. The firm also assists clients within criminal proceedings involving tax evasion. Oleg Vdovychen, managing partner, is the main contact.

ANTIKA Law Firm offers legal support to clients in tax dispute resolutions. Their recent activities include challenging judicial decisions regarding reductions in VAT budget refunds and the application of financial penalties, representing clients and company officials within the framework of criminal proceedings in connection with tax evasion. Oleksandra Fedorenko is a tax partner. The key senior team includes Mykhailo Voitsekhovskyi and Vasyl Sheretko.

Ukrainian law firm Armada expands its offering of tax advisory and litigation services. The FORCE group of companies engaged the firm for advice on reporting for controlled foreign companies and tax structuring of export activities of affiliated companies, which included compliance analysis, submissions to the Ukrainian tax authority and development of tax structuring schemes in accordance with Polish and German tax laws. The firm represented the interests of Metalsplavtechnology LLC in challenging the decision of the Regional Tax Commission classifying the client as a high-risk VAT payer. Anastasiia Luuk is the lead partner.

Ukrainian law firm MK Legal Service has a vivid industrial focus, namely – IT, TMT, retail and FMCG, and HoReCa, as well as private clients. In 2022-2023, the team supported international business structuring and the successful entry of GigaCloud, Ukrainian TMT leader onto the world arena, alongside relocation of some of its capacities to Poland. Given the firm’s rich portfolio of HoReCa clients, the team is experienced in handling tax disputes, managing issues with fictitious contractors, providing assistance in removing firms from risky entrepreneur lists, unblocking tax invoices. The team represented BVE TRADE in the course of its wrongful inclusion on the State Tax Service of Ukraine’s risky taxpayer list by analyzing the situation, ultimately restoring the client’s ability to receive payments out of court. The team is generally guided by Maksym Kurochko, the firm’s managing partner. Serhii Husiev, head of HoReCa and the retail support practice, and Artem Ostapenko, head of IT/TMT practice, direct activities within their respective sectors.

NOBLES specializes in handling commercial transaction structuring, ensuring currency control compliance, managing debt assignment and settlement, and overseeing profit and investment repatriation. The firm also addresses challenges in import/export relations, executes sophisticated cross-border payments, and navigates other intricate tax-related issues. Most recently the tax team advised on the taxation of share transfer, VAT credit issues, on contractual VAT issues and tax matters, arising from an intra-group reorganization, taxation of incentive programs for employees/contractors. The firm’s clients include Ivoclar Vivadent, Beam Suntory, BayWa, H&M Hennes & Mauritz, AUTO1 Group, Llentab, DAAD: German Academic Exchange. Alexander Weigelt and Volodymyr Yakubovskyy are lead partners.

Pragma Consulting Group, a firm focused on GR service, provided advice on a series of legislative changes. The firm advised on the Draft Law of Ukraine that simplified the import, accounting, and distribution of humanitarian aid (enacted in December 2023), ensuring the status of recipients from the introduction of martial law, expanding tax benefits and classifying purchased aid as tax-exempt; provided legal support to the retail industry in advocating for the adoption of amendments to the Tax Code of Ukraine, facilitating the use of generators during blackouts. Alyona Shulima, managing partner, is the main contact.

AEQUO* possesses a comprehensive tax practice that includes advisory services, transactional support, and litigation. Vasyl Mishchenko, the firm’s counsel, was deemed to be a notable tax practitioner.

AVELLUM’s* tax practice, led by Vadim Medvedev, stands out for its expertise in transactional tax support within M&A, wealth structuring, and international tax planning.

A1 Consulting* is a known name for transfer pricing matters.

Ukrainian law firm GOLAW* is renowned for its longstanding expertise in tax legislation. The firm’s partners, namely Iryna Kalnytska and Valentyn Gvozdiy, are well-known figures in the industry. The firm’s litigators were noted for their active performance in courts within the research period.

Regional Counsel 

Odesa-based law firm Legrant traditionally acts for exporters, traders, stevedore companies, rendering representation in tax disputes. During the research period the firm handled multiple tax litigations challenging the notice-decisions of the State Tax Service of Ukraine involving allegations made by the former of fictitious transactions, violations of tax and currency legislation, improper audit assessments, issues with VAT calculations, and disputes over set-offs and document seizures during audits. Nataliia Makovetska acts on tax issues. Tatiana Titarenko, managing partner, is the main contact.

Kharkiv-headquartered Shkrebets & Partners has built a reputation for managing a substantial volume of tax disputes, making it the favored choice among major regional industrial clients, state-owned and municipal-owned enterprises. The firm’s proven track record prominently includes handling complex challenges related to tax liabilities. PJSC Kharkiv CHP-5 and Zhylkomservice are long-term clients of the firm. The practice is led by partners Evgeniy Shkrebets and Yuriy Artukh.

[1] Firm’s tax partner Svitlana Musienko joined PwC Sweden as a senior tax counsel. Counsel Dmytro Korbut moved in-house.

[2] Illya Sverdlov, partner, departed in July 2023.

[3] Tax partner Oleksandr Markov joined the Armed Forces of Ukraine. In June 2024, he rejoined the firm.