Karina Pavlyuk

PRACTICE FOCUS

Ms Pavlyuk has over 12 years of experience in international tax planning, corporate structuring, compliance procedures and interaction with banks.

She participated in projects on restructuring a business model for a network of medical diagnostic centers in Ukraine; for a battery manufacturer (the largest manufacturer in Eastern Europe); for a manufacturer of metal packaging (one of the largest manufacturers in Ukraine, the CIS countries and the European Union).

Karina specializes in supporting projects on corporate restructuring, business redomiciliation, international mergers and acquisitions, the formation of a history of the “source of funds”, and supporting the entry of a foreign investor into the Ukrainian market. Karina Pavliuk’s areas of expertise include:  

• International tax planning, assessment of tax risks in corporate structures, assets protection and business structuring to multinational companies. Dealing with income repatriation (dividends, interest income, royalties), funding of Ukrainian business, currency issues. Double tax treaty qualification, with due regard for the requirements of multilateral instrument (MLI) (principal purpose test, “look through approach” and other anti-avoidance measures) and BEPS Action Plan;
• Analysis of cross-border transactions from perspective of applicability reporting requirements to them (in terms of EU Anti-Tax Avoidance Directives);
• Permanent establishment risks assessment in Ukraine. Identification of e-commerce PE risks in EU countries;
• Assistance to individual businessmen in participation of tax amnesty campaign in Ukraine;
• Consulting regarding CFC regulations in Ukraine. Tax diagnostics of current business models and advising clients on their restructuring;
• Assistance with “tax-free liquidation” of non-resident companies and declaration of liquidation proceeds in Ukraine (in terms of recently established fiscal norms);
• Preparation of opinions as to non-resident companies for Ukrainian banks, in order to confirm their legal capacity to act as sureties, guarantors before the Ukrainian banks (in connections with loans provided to Ukrainian businesses);
• Dealing with labor law and data protection issues (obtaining work permits and residence permits for expats, assistance to foreign investors with participation in Diia City Project);
• Cooperation with foreign banks (in terms of opening and maintaining private and corporate bank accounts), assistance to clients with compliance procedures;
• Participation in M&A transactions;
• Procuring due diligence reports of Ukrainian companies;
• Legal assistance to local companies (procuring various registration actions, advising on labor regulations, contractual work, advising on regulatory, licensing and consumer protection requirements, dealing with various corporate and commercial law issues).