International Taxation | KPMG | UA

International corporate taxation and foreign trade regulation services

International Taxation

KPMG professionals help our clients in finding answers to and resolving complex issues and problems in the spheres of international corporate taxation

We help our clients in finding answers to and resolving complex issues and problems

KPMG professionals help our clients in finding answers to and resolving complex issues and problems in the spheres of international corporate taxation, as well as regulation of foreign trade, including issues of customs clearance of goods and equipment


International corporate taxation and international trade regulation practice of KPMG in Ukraine is one of the professional practices in tax and legal department of KPMG Ukraine, with offices in Kyiv, Lviv, Odessa and Kharkiv.

We assist companies with risks mitigation in relation to international corporate taxation and international trade by providing the following services:

  • Diagnostics and providing advice/solution on a possibility or efficiency of usage of the international agreements of Ukraine in the spheres of taxation, foreign trade regulation, and customs regulation in particular;
  • Represent interests in regulatory authorities on the issues of international corporate taxation and international trade as an authorized representative, in particular, in the following cases:
    • audits or procedure for appealing against the decisions, actions or omissions of the regulatory authorities;
    • preparation and provision of explanations on issues that arise during such audits or appeals;
    • review and obtaining of official documents (certificates) on audits in the regulatory authorities;
    • signing official documents (information) on the audit, and in case of any comments on the content (text) of prepared documents (certificates) – advise to sign them with a proviso;
    • preparation and submitting of written objections to acts (certificates) of such audits to controlling agencies;
    • requirements and verification of data and facts that may argue for the clients;
  • Prepare requests for obtaining and receive:
    • individual rulings of controlling agencies on the practical application of tax and customs legislation of Ukraine on international corporate taxation and international trade;
    • preliminary decisions of the customs authorities in respect of: (i) the classification of goods under UKT ZED (Ukrainian Classification of Commodities for Foreign Economic Activity), (ii) determining the country of origin of goods, (iii) placing of goods under a certain customs regime;
  • Diagnostics of tax expenses related to a foreign element and provision of opinions on the effective management of the expenses, as well as support of client decisions made on the basis of such opinions;
  • Diagnostics of tax and customs implications, compliance with other legislative requirements in relation to the change in tax status in Ukraine or abroad for activities undertaken (commercial/non-commercial) in Ukraine, as well as the implementation of foreign trade operations;
  • Comparative analysis of foreign jurisdictions on tax, customs and other factors for choosing a jurisdiction to do business in Ukraine, given recent trends on BEPS (the Action Plan on Base Erosion and Profit Shifting) and CFC (the rules for Controlled Foreign Companies);
  • Review of tax structures of the asset ownership through related entities;
  • Diagnostics and offer of options for the transfer of assets in Ukraine (into direct ownership of the UBO);
  • Diagnostics of risks in relation to currency control and other legislation concerning foreign trade operations;
  • Obtaining certificates of tax authorities on taxes paid in the Ukraine and / or abroad;
  • Registration, maintenance and de-registration of representative offices of non-residents in Ukraine;
  • Identification and confirmation of the tax status of representative offices of non-residents in Ukraine;
  • Registration of international technical assistance projects in order to receive benefits under tax, customs and currency legislation;
  • Diagnostics of business models that provide for income payments to non-residents;
  • Supporting the payment of dividends, interest, royalties: diagnostics of a case and related documents, proposal for preparation and preparation of necessary documents, the communication with directors and regulatory authorities, assistance in obtaining certificates on taxes paid in Ukraine and / or abroad;
  • Examination of documents submitted to custom authorities for customs clearance, i.e., determination of customs value, examination of documents’ completeness and compliance with current legislation;
  • Assistance in communication with customs authorities in the process of customs clearance of goods;
  • Advising on the application of tax, customs, and other legislation in the field of foreign trade, as well as its changes in other jurisdictions.

Our International Corporate Taxation and Foreign Trade Regulation professionals actively cooperate with other departments and divisions of KPMG in Ukraine, including our regional offices in Kharkiv, Lviv, and Odessa, as well as with the global network of KPMG offices in more than 150 countries. KPMG professionals employ local and global experience and opportunities of KPMG in these and other spheres and areas of corporate counselling.

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