Identification of risks related to new regulatory requirements

Legislative changes in Ukraine and abroad can create various risks for businesses, including that of challenging applicability of tax benefits provided for by double taxation treaties. Our team will help to identify such risks and mitigate or eliminate them.

Tax authorities across the globe are increasing their efforts in combating abuse of preferential tax treatment for international transactions. Requirements for countering such abuse are implemented both nationally and internationally, which reduces the efficiency and applicability of traditional mechanisms of and approaches to tax planning.

In light of changes in legislation and practices, it is crucial to timely identify and mitigate tax risks that may affect businesses, including that of challenging applicability of the tax benefits provided for by double taxation treaties, etc.

Deloitte's International Tax team provides a wide range of services to its clients, including:

  • Diagnostics of the existing organizational structure of a business for tax risks based on effective legislation, international treaties, OECD best practices, BEPS Action Plan, legislative initiatives on “deoffshorization”, international information-sharing initiatives, CRS/FATCA practice, European anti-money laundering initiatives, DAC6 impact assessment etc.
  • Recommendations on how to ensure the required presence (“substance”) of a company in a foreign jurisdiction, both in terms of compliance with local legislation and risk mitigation of failure to apply preferential tax rates of withholding tax on the relevant income
  • Recommendations on improvement of international tax model
  • Assistance with preparation of the defence files (beneficial owner and/or principle purpose tests)


Andriy Servetnyk

Andriy Servetnyk

Partner, Tax & Legal

Andriy Servetnyk is a Partner of Tax & Legal. Since 2002, he has been working for Deloitte and is now in charge of International Tax and Deloitte Private. Andriy is a Certified Attorney-at-Law, specia... More

Natalia Rudenko

Natalia Rudenko

Senior Manager, Tax & Legal

Natalia Rudenko is a Senior Manager in Tax & Legal Department, International Taxation Group, Attorney. Natalia has over 15 years of experience providing services in corporate law and international tax... More

Mariia Sybyriakova

Mariia Sybyriakova

Manager, Tax & Legal

Mariia joined Deloitte in 2010 and has gained a considerable experience in Ukrainian and international tax. Mariia holds a degree in law and specializes in consulting on restructuring of international... More