K.A.С. Group Attended Cocktail Reception for Owners of Foreign Companies

What awaits beneficiaries of foreign entities in 2025?

Junior partners of K.A.C. Group — Volodymyr Sytnik and Iryna Matsapura — joined the Cocktail Reception for Owners of Foreign Companies, where some of the most pressing issues of CFC legislation and international business structuring were discussed.

Among the key topics there were:

—Case law and State Tax Service consultations on CFIC — what influences approaches in structuring?

—Taxation of “through dividends”: personal income tax or repatriation tax?

—Challenges of CFC reporting: permanent representation through a Ukrainian director

—Taxes on undistributed profits: CFC and challenges

—STS audits, inquiries to foreign companies and “happiness letters” to clients

—Resident status when “residing in two countries”: how to choose a reporting strategy

—Influence of relatives on CFC control

Panel II also discussed the risks of unregistered permanent representations and their consequences for companies:

— Fines and tax assessments

— Risks for startups when structuring

— Cancellation of the preferential rate for payments under conventions

— Substance assessment and tax audits

We express our gratitude to the organizers of the event for the high-quality expertise, wonderful atmosphere and important discussion!