Permanent establishments and non-residents: issues of registration, cooperation and tax audits

Changes in taxation of permanent establishments, registration of non-residents, business purpose test require the special attention of business representatives that work with non-residents, and in certain cases a complete revision of the company’s activity, to avoid fines.

Partner at GOLAW, Attorney at Law Iryna Kalnytska and Senior Associate at GOLAW, Attorney at law Olena Sulyma will discuss the latest changes with practical examples and analyze in detail the problematic issues that arise in non-residents’ representative offices, Ukrainian companies cooperating with non-residents, and actually foreign companies with business presence in Ukraine.

Topics do discuss:

• Keynotes of cooperation with non-residents from 2021 (risks of PE, business purpose, mutual agreement procedure): Case study
• Re-registration of permanent establishments: what should do those who did not meet the deadline?
• Problematic aspects of non-residents’ registration and tax payment: answering questions
• Tax audits of non-residents: features of conducting and appeals
• Request from tax authorities on non-residents: how to respond properly?

Please note that prior registration is required.

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Iryna Kalnytska – Partner at GOLAW, Attorney at law

Iryna Kalnytska is the Head of Tax, and Restructuring, Claims and Recoveries practices at GOLAW. Iryna advises Ukrainian and global companies on national and international taxation, tax risks mitigation, tax structuring. She successfully represents the interests of clients in complex tax disputes.  The lawyer also has a strong background supporting banks and insurance agencies in the provision of debt finance, as well as in other various aspects of the finance industry, including debt restructuring and refinancing.

Olena Sulyma – Senior Associate at GOLAW, Attorney at law

Olena Sulyma is the Senior Associate at GOLAW. Olena advises Ukrainian and foreign companies on taxation. In particular, she carries out the analysis and assessment of tax aspects and risks of the business transactions and activity. Olena successfully represents the interests of the firm’s clients before tax and other supervisory bodies, provides legal supports during tax audits, pre-trial settlement of disputes, and litigation disputes of different specializations. The lawyer also focuses on the issues of protection of intellectual property rights, companies’ compliance with the legal requirements of advertising law and on consumer rights protection.