ArtesLex combines deep expertise in tax law with a practical approach to protecting taxpayers, allowing our clients to act with confidence in their tax and legal decisions. With extensive experience in domestic and international taxation, we provide a full range of services including tax planning, optimization of tax structures, representation before tax authorities during audits, administrative appeals of tax assessments, tax litigation, and criminal tax defense of company executives before investigative authorities. We help our clients efficiently plan tax obligations, minimize risks, prevent additional tax assessments, and safeguard their interests in any tax disputes.
Among the wide range of services provided by our firm in the field of taxation, the following may be distinguished:
Tax Planning and Optimization
- Consulting on domestic and international taxation and the application of double taxation treaties;
- Structuring transactions and corporate operations with due regard to tax implications;
- Analysis of tax risks in investment projects and M&A transactions;
- Advising on tax risks in various business sectors and specific commercial transactions;
- Support in tax compliance procedures and internal audits.
Specialized Tax Services
- Advisory on transfer pricing, controlled foreign companies (CFCs), and comprehensive legal and documentary support;
- Tax due diligence of contractors and counterparties to avoid tax risks;
- Tax due diligence of enterprises (pre-acquisition or compliance reviews);
- Advisory for foreign companies and investors regarding Ukraine’s tax regime;
- Consulting on international taxation and cross-border tax planning.
Transfer Pricing
- Advisory on transfer pricing rules and tax planning strategies;
- Preparation of controlled transaction reports;
- Drafting and support of transfer pricing documentation;
- Legal risk assessment and evaluation of potential tax consequences;
- Support during inspections by tax authorities;
- Representation in transfer pricing disputes with tax authorities.
International Taxation
- Advisory on the application of double taxation treaties (DTTs);
- Tax planning for multinational enterprises, international groups, and permanent establishments of non-residents;
- Legal and tax support for international investments, cross-border financing, lending, and corporate transactions, with a focus on tax implications in different jurisdictions;
- Structuring and optimization of intragroup financial flows and cross-border tax planning;
- Advisory on the rules of Controlled Foreign Companies (CFCs) in Ukraine and their interaction with similar regimes in other tax jurisdictions;
- Advisory on the implementation of international tax standards (including OECD, BEPS and EU initiatives);
- Tax risk assessment for companies entering international markets and engaging in foreign trade activities;
- Advisory on the taxation of digital services, cryptocurrencies, and e-commerce operations with a cross-border element;
- Representation and legal support in tax disputes arising from international transactions and cross-border financial flows.
Relations with Tax Authorities
- Advisory on the conduct and procedures of tax audits;
- Support during tax inspections and negotiations with authorities;
- Preparation of objections to tax audit reports;
- Administrative appeals of tax notifications-decisions, including drafting complaints and procedural documents.
Tax Dispute Resolution and Litigation
- Preparation of claims and procedural documents in tax litigation;
- Representation of clients before courts of all instances;
- Strategic support in complex tax litigation processes.
Criminal Tax Defense
- Procedural defense of company executives in criminal tax investigations;
- Development of individual defense strategies, legal assistance during investigative actions, and representation by counsel in criminal proceedings;
- Appeals against procedural actions or inaction of investigative bodies;
- Representation before all courts in criminal tax cases.