The team of the ArtesLex provided legal advisory support to an international group of companies in connection with the need to analyze tax risks arising in the course of long-term secondments of employees to foreign jurisdictions under agreements on the provision of personnel to perform work for affiliated companies of the international group abroad.
The client requested the preparation of a legal opinion aimed at determining the legal and tax implications of such transactions, in particular in the context of compliance with the provisions of the Tax Code of Ukraine, international double taxation treaties, and transfer pricing rules.
In the course of providing advice, our lawyers conducted an in-depth analysis of possible qualification approaches to secondments of employees to foreign jurisdictions for the performance of long-term assignments and paid special attention to the requirement of obtaining additional permits necessary for rendering such services.
As a result of the consultation, the client received clear and practical recommendations on structuring internal policies and documentation to minimize risks associated with sending employees abroad, as well as on the proper drafting and support of agreements on the provision of personnel to perform work for affiliated companies. Particular emphasis was placed on the importance of aligning the terms of such agreements with the provisions of double taxation treaties and ensuring the correct reflection of the transactions in tax and accounting records.
Thus, thanks to the comprehensive approach and thorough analysis of national and international tax law, the client obtained the opportunity to properly structure its activities, ensuring the minimization of tax risks and compliance with legal requirements in the field of international business operations.
03.09.2025
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