BUSINESS STRUCTURING 2026

PRAGNUM Discusses Corporate Risk Mitigation and Asset Protection Amid Upcoming Tax Reforms

Businesses are increasingly forced to reconsider their conventional operating models – not only from a tax perspective, but also within the context of corporate security, beneficial owner liability, and long-term resilience. Structures that were considered standard yesterday are rapidly becoming a source of vulnerability for entrepreneurs today.

Although the introduction of VAT for private entrepreneurs has been officially postponed, the market already perceives these legislative shifts as a matter of time. Consequently, we recommend utilizing this period as a strategic window to prepare for imminent regulatory changes.

Recently, we have seen a surge in client inquiries regarding how to mitigate risks associated with corporate fragmentation, protect personal assets in 2026, and safeguard interests in relationships with partners and investors.

Therefore, PRAGNUM recently hosted a business breakfast for Ukrainian business owners to discuss defense strategies in anticipation of the legislative changes expected by 2027. Our experts not only highlighted potential threats but also shared practical frameworks for minimizing tax, criminal, and corporate risks, alongside actionable approaches to asset protection under various legal models.

The discussion centered around key issues currently facing the business community, including:

• Audit of Private Entrepreneurship Models: How to maintain the line between lawful tax optimization and illegal business fragmentation in 2026.
• Transition from Private Entrepreneurship to LLC Structures: Tax implications, identifying when transformation becomes necessary, and how to execute it seamlessly.
• Partnership Security: Conducting legal due diligence on partnership arrangements and structuring 50/50 corporate setups to protect companies from deadlocks.
• Personal Liability: Demarcating corporate risks from the personal liability of directors and owners for company debts, particularly in insolvency and bankruptcy proceedings.
• Exit Strategies: Optimal approaches to the liquidation of LLCs and private entrepreneurships, focusing on the legal consequences for management and shareholders.

“Today’s business breakfast was highly engaging and dynamic,” commented Vitaly Bobrynev, Managing Partner of PRAGNUM. “We addressed the critical, real-world challenges that Ukrainian companies are currently facing. We started with discussions around private entrepreneurship structures and ultimately moved toward M&A-related matters. The choice of organizational and legal structure is no longer merely an operational decision. Continuing to operate under outdated models is still possible, but it becomes increasingly difficult and risky with each passing month. That is why businesses must already begin evaluating the reliability of their legal structures and preparing for change in a systematic way.”

The event also featured presentations by PRAGNUM Partner Oleksii Nekrasov, Counsel Oleksandr Mostovyi, and Senior Associate Alyona Michurina. Each session included analysis of real-life cases and practical scenario modelling.

We thank all participants for their insightful questions and active professional dialogue.

Receive an expert assessment of your business structure and recommendations for its adaptation to current regulatory requirements — Contact PRAGNUM