Workshop TaxHUB 4.0 "Intercompany Recharges: Application of Allocation Keys within Contract Documentation"


Recognition and payment of expenses on intragroup services always was a disputable issue for Ukrainian companies. Usually, Ukrainian companies compensate expenses on intragroup services relying on the approach of expenses calculation based on the hourly rates of specialists, directly involved in such services provision.

Confirmation of mentioned expenses for the tax authorities is a matter for Ukrainian companies due to difficulties in preparation of respective reports and supporting documents.

Usage of allocation keys within contract documentation simplifies preparation of supporting documents package, resolves issue of services calculation cost and reveals the substance of received services.

During the Workshop, Deloitte specialists helped participants to understand following questions:

  • Substance of allocation keys, advantages of their application, issues associated and how these issues are resolved
  • Confirmation of expenses in intragroup services by means of allocation keys
  • Approach of tax authorities and available court practice regarding application of allocation keys
  • Currency control regulation of payments abroad


During the workshop, participants had an opportunity to evaluate practicality of allocation keys application within their companies, better understand the tax authorities’ approach to the analysis of intragroup expenses and consider potential tax risks in Ukraine.


Deloitte speakers:

Vladimir Yumashev, Partner, Tax and Legal department. Vladimir has more than fifteen years of experience in taxation. He specializes in M&A transactions, investment planning, international structuring, review and due diligence projects. He deals with detection and elimination of tax risks, as well as identification of tax planning opportunities for legal entities aimed at taxes burden minimization.

Dmytro Pavlenko, Director, Tax and Legal department. Dmytro is a leader of legal team. He has more than fifteen years of experience and specializes in corporate, contract, antimonopoly, labor and intellectual property law, as well as on customs, litigation and other legal issues. He is Attorney-at-Law and has PhD in Law.

Sergey Onischenko, Senior Manager, Tax and Legal department. Sergey has more than ten years of experience in providing tax consulting services. He specializes in tax audits and reviews, support of companies during tax audit initiated by tax authorities, companies’ transformation to IFRS, tax consulting services and providing professional tax advises covering a variety of Ukrainian and international tax issues.

Andriy Zelenskyy, Manager, Tax and Legal department. Andriy has over seven years of taxation experience in Ukraine. He specializes in tax audits and tax reviews, tax due diligence, preparation of tax returns, has significant experience in provision of professional tax consulting services on corporate taxation and accounting matters.

Viktoriia Sydorenko, Manager, Tax and Legal department. Viktoriia joined Deloitte in 2016. She specializes on corporate and labor law and has significant experience in financial sector matters. Viktoriia has experience of full legal support of companies in agro, financial, media and real estate sectors.


Workshop has been organized jointly with: