International Tax Planning and Structuring

Structuring Ukrainian and Foreign Parts of the Business for Beneficiaries

By 2025, the vast majority of countries will have fully adopted the rules of total tax transparency of BEPS, CRS and MLI. All (!) information about the person (in the financial part) will be published and looped, including data of the previous tax return, any received income in any country of the world by an individual or a beneficial owner of businesses, and expenses they incurred. At the same time, such factors as tax residency of a person, center of their economic interests, correlation of tax rates, throughout their business chain ending with them as a physical person, are taken into account. As a result, based on all the information above, they receive an invoice for taxes as a monthly receipt for payment from the Housing Office.

K.A.C. Group experts have developed a set of measures for the legalization of financial instruments (for international business companies and bank accounts) in the legislative field of Ukraine, where the key point is the interests of the beneficiary who is a resident of Ukraine (and, in one way or another, is involved in financial instruments) under the conditions of BEPS, MLI and global exchange of information.

The main task that our customers have been solving together with us throughout all the years of our cooperation has been coming up with the optimal structure for managing/owning businesses from the point of view of security and tax optimization. In addition, the following concerns are considered:

• Solving issues of legalization of a citizen of Ukraine as a beneficiary of businesses in Ukraine and abroad, including the businesses that were created earlier.
• Formation of the beneficiary’s income history.
• Structuring the business and the income from it for Ukrainian citizens, beneficiaries of non-resident companies, in the future.

There are certain options that can be applied: from structuring the entire business scheme (in Ukraine and abroad) with the removal of points of “doing business”, points of “tax payments” and points of “personal economic and vital interests” to optimal tax jurisdictions, to a simple change of tax jurisdiction by the beneficiary. In any event, these matters are analyzed and solved in a purely individual manner, based on the specifics of a particular case.

If you have any questions about opening bank accounts abroad, business structuring and legalization of beneficiaries in Ukraine, please contact the K.A.C. Group office, where you will receive detailed professional advice on the issues of interest to you.