Format: masterclass

Speaker:
🎤 Dmytro Mikhailenko – Managing Partner at Crowe Mikhailenko. President of the Association of Tax Consultants. Legal Adviser to the IT Committee of the European Business Association. Member of the EBA’s Kharkiv Finance and Tax Committee. Member of the Expert Council at the Ministry of Finance of Ukraine on the preparation of general tax rulings. Head of the working group at the Ministry of Finance of Ukraine on the preparation of general tax rulings. Member of the non-governmental organisation “IFA Ukraine”. Legal Adviser to the International Finance Corporation (World Bank Group).

Question:
1) Foreign holding company:
• What are the options for forming the authorised capital: contributing shares or purchasing them at par value (as a typical approach for offshore/affiliated structures)?
• Which jurisdictions should be considered: Cyprus, Malta, the UK, Estonia; are the UAE and the Netherlands suitable?
• Key selection criteria: taxation of incoming/outgoing dividends, sale of the business, interest, royalties.

2) Ukraine: UBO, CFC, dividends, sale:
• What are the tax risks for UBO residents in Ukraine?
• How to structure the interaction between the CFC and operating companies: a separate structure for dividends and a separate one for sales with subsequent distribution to the holding company?
• How are pass-through dividends and the taxation of non-resident income applied?
• What are the options for selling “immovable” shares: through a subordinate CIF or through an individual?

3) Residency and family:
• Which jurisdictions should be considered for UBO residency: Cyprus, Portugal, the UAE?
• What are the tax implications and reporting requirements for a CIF if one participant is a resident and the other is not?

4) Interaction with Ukrainian regimes:
• How do CIFs and Diya.City (the NVC regime) integrate into the overall structure?

5) Family office and instruments:
• Which form is appropriate: a corporation, different classes of shares, dividend/reinvestment mechanisms, or the transfer of assets by inheritance via corporate instruments?
• Should alternatives be considered: a fiscally transparent entity, a trust, a foundation, an investment fund, or a separate personal office for each participant?

Moderator:
Mykhailo Kolisnyk

Event schedule:
18:00–18:30 Welcome coffee break
18:30–20:30 Masterclass
20:30–21:00 Closing

The event is part of the CFO CLUB UKRAINE programme. If you are not a member of the club, a ‘Guest Visit’ is available for you. You may use this once. The Guest Visit is valid for CFOs only. The organisers reserve the right to refuse participation, as the number of guest places is limited.

We will be happy to answer your questions.
Please call +38 067 192 48 67, Svitlana Vikarenko