International Tax Structuring Strategies for Ukrainian Business in 2013 March 28, 2013 Radisson Blu Hotel Kyiv, Ukraine
ORGANISERS INFORMATION INVITATION TO INTERNATIONAL TAX SEMINAR Hosting Branch IFA Ukraine IFA Ukraine is the Ukrainian branch of the International Fiscal Association (IFA). IFA Ukraine is a non-profit organization established in Ukraine in 2007. IFA Ukraine was officially recognized by IFA at the 61st IFA Kyoto Congress during September 2007. IFA Ukraine is the only organization in Ukraine dealing exclusively with international tax matters. IFA Ukraine has grown in a short time to over 50 members. www.ifa-ukraine.org Co-organizer IFA Netherlands IFA Netherlands is a Netherlands Branch of International Fiscal Association. Organization brings together tax managers and tax consultants who are participating both directly and indirectly in the activities of Central IFA. Since its inception, IFA Netherlands provided a blend of comprehensive research of international taxation and initiatives of current practical importance to the benefit of its Members and international peers. Central IFA International Fiscal Association (IFA), Netherlands, is the only non-governmental and non-sectoral international organization dealing with fiscal matters over the globe. IFA brings together more than 12,000 practitioners, tax officials and academics from 100 member countries, involved in and concerned with taxation of international transactions and comparative study of tax laws. Based in Rotterdam, IFA, since its foundation in 1938, has provided, in conjunction with the activities of each country branch, a blend of comprehensive research of international taxation and the development of programs and initiatives of current practical importance. Dear Colleagues! IFA Ukraine takes a pleasure of inviting you to the International Tax Seminar, jointly organized by IFA Ukraine and members of IFA Netherlands. This event is designed to serve as a platform for in-depth discussion of international tax issues arising in-between Ukraine and the Netherlands and matters of the UK tax legislation which could be of particular importance for Ukrainian business. The Seminar program will deal with the most influential tax rules and concepts affecting cross-border deals and structures, and will provide not only a practical overview of the current Ukrainian practice on the matter, but also insights and opportunities available in transactions of Ukrainian companies with Dutch and the UK counterparties. Perspective of other jurisdictions will also be presented. Senior-level tax advisors from Ukraine, the Netherlands and the United Kingdom will present a cohesive coverage of the topics of mutual interest and importance, including the recent legislative and administrative developments. Speakers will have time to address specific questions from the attendees regarding specific fact patterns or issues. The Seminar will take place at Radisson Blu Hotel in Kyiv, Ukraine. We look forward to making your participation in this joint seminar meaningful to you and your professional development and our Association s growth. www.ifa.nl Sincerely, Oleh Marchenko President IFA Ukraine
SEMINAR SPEAKERS SEMINAR SPEAKERS Vakhitov, Roustam Partner, International Tax Associates B.V. (The Netherlands/Russia) Terry, Andrew Senior Tax Partner, Withers (UK) Bilyk, Svitlana Director, Tax and Legal Services, PricewaterhouseCoopers Ivanusa, Dmytro Counsel, Sayenko Kharenko Roustam Vakhitov is an expert in international taxation Before joining International Tax Associates B.V. Roustam worked for consulting companies in Russia, the Netherlands and Luxembourg. He has been addressing international taxation issues since 2002, after obtaining LL.M. degree in International Taxation from Leiden University (The Netherlands) Specialization: international taxation, tax structuring and consulting with the use of international tax treaties, supporting transactions with the use of financial instruments, structuring private investments (funds) and supporting international mergers and acquisitions, as well as Islamic finance transactions. Roustam is a member of International Fiscal Association (IFA) and of the Dutch Chamber of Tax Consultants Register Belastingadviseurs. Andrew is a Senior Tax Partner at Withers and is the head of the firm s international corporate tax practice in London as well as jointly heading up the firm s CIS practice group. He qualified as a solicitor in 1984 and since 1985 has practised tax law in the City. He is experienced in all aspects of international and UK domestic corporate tax law (both direct and indirect). He has a deep interest in VAT and was a member of the original VAT Practitioner Group. He also advises ultra high net worth families based outside the UK on personal tax planning issues and the establishment of offshore trusts. During her 16 years with PricewaterhouseCoopers Ukraine Svetlana has provided tax advice, tax review and audit services for state and private companies, including multinational corporations in a variety of industries, including manufacturing, retail and consumer, pharmaceutical, real estate, banking and insurance, telecommunications. She specializes in advising local and multinational clients on the structuring of investments, on considering investment opportunities, developing business strategies, reviewing domestic tax compliance, performing financial restructuring and tax planning. Mr. Ivanusa focuses on taxation, currency control, foreign trade and customs. Dmytro Ivanusa also practices in corporate, M&A, dispute resolution, concessions, real estate, commercial law, labor law and sports law. Mr. Ivanusa is among Top 5 recommended tax lawyers according to Yuridicheskaya Praktika, a Ukrainian legal newspaper. He practiced law from 1996 at the Kyiv offices of KPMG, Baker & McKenzie, CMS Cameron McKenna and at a Ukrainian boutique law firm Levenets, Maciw & Partners. The tax practice created by Mr. Ivanusa at CMS Cameron McKenna has been recommended by the Legal 500. Vitko, Anna Senior Consultant, KPMG Medvedev, Vadim Associate, Avellum Partners Popov, Boian Partner, IFAA (The Netherlands) Musienko, Svitlana Partner and Head of Tax, DLA Piper Anna Vitko is a lawyer with more than seven years of professional experience in legal field. She specializes in advising multinational and local clients on various international tax issues. Prior to joining KPMG in 2011 she obtained LL.M in European and international tax law from Lund University, Sweden, and LL.M in European law from Stockholm University. In 2012 Anna worked at KPMG Russia as an international secondee within the International Corporate Tax Group. Admitted to Ukrainian bar since 2008. Vadim is an Associate with Avellum Partners with the primary focus on the areas of taxation, customs and currency control. He also specializes in general corporate and commercial advice. Vadim regularly advises international and Ukrainian companies on various aspects of their business activities in Ukraine and represents them in the courts and before tax and customs authorities of Ukraine. His industry-specific experience includes work with Pharma, FMCG, Real-Estate, IP and Banking clients. Vadim holds a specialist of law degree from the National University Kyiv-Mohyla Academy. He actively participates in initiatives of the Tax Committee of American Chamber of Commerce in Ukraine. Boian is an all-round adviser in the Dutch international tax practice with an extensive experience in international taxation and the coordination and implementation of various global projects. Before joining IFAA as a tax partner in 2009, he worked for more than eight years for KPMG and Ernst & Young, where he primarily advised multinational corporate clients. During his Ernst & Young period he worked for the Dutch Desk of Ernst & Young in London providing advise to American corporate clients, as well as America based private equity and real property funds on the tax aspects of European investments. At the Amsterdam practice of Ernst & Young he was a member of Multinational Tax Department focusing on the development and implementation of tax efficient structures involving the Netherlands. He became a manager in the Ernst & Young Multinational Tax Department in 2009. Svitlana Musienko is Partner and Head of Tax practice of DLA Piper. She advises on domestic and international tax planning, corporate law and investment structuring. Svitlana has 14+ years of professional experience behind her in the field of tax and law. Before joining DLA Piper, she was with Ernst & Young s Kyiv office as a senior manager of its tax and legal practice. Prior to that she was with Arthur Andersen. Svitlana has a master s degree in the Legal Regulation of Economics from the Kyiv National University of Economics. Svitlana Musienko is personally recommended for tax in Ukraine by the Ukrainian Law Firms 2012, A Handbook for Foreign Clients and named as a leading tax practitioner by PLC Which Lawyer? in 2012/2013. DLA Piper Ukraine is shortlisted for the Tax Law Firm of the Year in Ukraine 2012 by the International Tax Review and ranked in leading international directories including Legal 500, Chambers Europe and World Tax.
Thursday, March 28, 2013 8:30 9:00 Registration 13:00 13:30 Networking Coffee Break 9:00 9:10 Welcome Address 9:10 11:10 Tax structuring of financing activities Brief overview of tax regime applicable to financing activities; Thin capitalization rules (incl. Ukrainian court cases); Transfer pricing rules; Beneficial ownership test; Other deductibility restrictions (incl. Ukrainian court cases); Anti-abuse rules and anti-avoidance concepts applicable to financing activities; 11:10 11:30 Networking Coffee Break 11:30 13:00 Tax structuring of IP-holding / royalty-flow Brief overview of tax regime applicable to royalty flow; Transfer pricing rules; Beneficial ownership test (incl. Ukrainian court cases); Other deductibility restrictions (incl. Ukrainian court cases); Anti-abuse rules and anti-avoidance concepts applicable to IP structures (incl. Ukrainian court cases); Dutch Sandwich structure (how it differs from mere use of an offshore company (as the case may be) and how this structure may be adjusted for use by Ukrainian companies); 13:30 14:10 Tax structuring of M&A transactions Brief overview of tax regime applicable to M&A transactions; Look-through approaches in the relevant jurisdiction; Anti-abuse rules and anti-avoidance concepts applicable to M&A; 14:10 14:30 Networking Coffee Break 14:30 15:10 How the Netherlands could be used for establishing holding companies? 15:10 Closing Brief overview of tax regime applicable to holding activities; Look-through approaches in relevant jurisdiction; Anti-abuse rules and anti-avoidance concepts applicable to holding companies;
SEMINAR REGISTRATION GENERAL INFORMATION Registration Office Payment Order Official Website Sponsorship For inquiries regarding registration and accommodation, please contact: IFA Ukraine Tel.: +380 44 2200711 Email: ifa@ifa-ukraine.org IFA Ukraine will email the invoice upon receiving electronic registration. All charges related to payments by bank transfers must be covered by the Participants. For detailed and updated Seminar information, we invite you to visit the IFA Ukraine website at ifa-ukraine.org If you are interested in sponsorship opportunities, please contact IFA Ukraine at ifa@ifa-ukraine.org. Accommodation Address: 4B Ivana Franko St. Kyiv, 01034, Ukraine Registration We invite you to register online. To activate online registration link please click here. Registration Fee Registration Fee for non-ifa Ukraine members: Euro 150. Cancellation Policy and Refund All cancellations must be submitted in writing to the IFA Ukraine. After March 15, 2013: no refunds are granted. Seminar hours 9 am 4 pm Official language The Seminar languages are Ukrainian and English. Sessions will be conducted in both Ukrainian and English. Simultaneous translation will be provided. Venue Seminar will take place at Radisson SAS Blue Hotel, Radisson Blu Hotel Kyiv, 22 24 Yaroslaviv Val St, Kyiv, Ukraine. Radisson Blu Hotel, Kyiv (Seminar Venue). 22, Yaroslaviv Val Str. Kyiv 01034, Ukraine Tel: +38 044 492 2200 Fax: +38 044 492 2210 reservations.kiev@radissonblu.com http://www.radissonblu.com/hotel-kiev Registration Inclusions Seminar registration includes participation in sessions, electronic access to technical papers and refreshments during seminar hours.
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