Workshop TaxHUB 3.0: "Concept of Beneficial Owner"


Constant changes in the national and international tax legislations bring up a challenge to big market players. Currently, questions of verifying of foreign company's "substance" and its status as a beneficial owner of Ukrainian income (e.g. dividends, interest or royalty) are in the spotlight.

Experts from the international taxation team of Deloitte, jointly with representatives of the State Fiscal Service and the Ministry of Finance of Ukraine helped participants to investigate this matter. We discovered the latest tendencies and discussed the following:

  • The concept of beneficial owner, criteria and purposes for determination of its status
  • Assessment of economic substance of a foreign company, its features and necessity to revise the position due to changing circumstances
  • Practical approaches for creation of "substance" of a foreign company in accordance with Ukrainian and other jurisdictions requirements
  • New definition of the "Principal Purpose Test" and its correlation with the beneficial owner status confirmation


These topics and even more were examined with relation to existing and potential changes of legislation as well as the latest Ukrainian court practice.

Also, during the workshop participants had an opportunity to participate in a simulation performance, modelling a request sent by tax authorities with respect to a foreign company. They were be able to play a role in the positions from both sides and, as a result, understand details of the process and relevant risks in Ukraine.


Deloitte speakers:

Andriy Servetnyk, Partner, Tax and Legal department. Andriy has more than 15 years of experience, primarily in the area of international taxation, structuring and Private Client Services. As a partner Andriy leads various projects including corporate and international tax consulting, planning and structuring of investments, tax aspects of entering international capital markets, mergers and acquisitions of business. 

Natalia Rudenko, Senior Manager, Tax and Legal department. Natalia joined Deloitte back in 2004 and has significant experience in corporate law and international taxation. Her area of specialization includes investment planning, tax restructuring of international and big Ukrainian companies (including agribusiness, food processing, retail, wholesale and distributions, healthcare and pharmaceuticals, IT), intellectual property, customs consulting, private client services.


Representatives of the Ministry of Finance of Ukraine and the State Fiscal Service of Ukraine:

  • Yevgeniy Kozlov, Advisor to the Minister of Finance of Ukraine
  • Natalia Ruban, Director of the SFS Audit Department
  • Oleksandr Lepetiuk, Deputy Head of the Large Taxpayers' Office of the State Fiscal Service of Ukraine



Organized jointly with: