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Specific tax law issues for businesses in Kyiv

PRAGNUM Law Firm – deep expertise in resolving atypical tax challenges for businesses.

PRAGNUM is a team of tax lawyers in Kyiv that deals with the most complex and specific tax law issues for businesses. We specialise in situations that go beyond standard tax advice: unblocking tax invoices, delays in VAT refunds, unlawful requests from the tax authorities, transactions with non-residents, dubious supply chains, transfer pricing and many other cases that require in-depth knowledge of the law, case-law and a real understanding of the client’s business logic. Our mission is not merely to solve the problem “today”, but to establish reliable, well-documented and practically applicable protection mechanisms that minimise tax risks and preserve the company’s reputation and liquidity in the long term.

When is our assistance required?

PRAGNUM Law Firm is engaged as an external tax adviser and procedural defender in a wide range of complex situations. Each of them has its own dynamics, legal specifics and risks which require an individual strategy.

Blocking of tax invoices. When the State Tax Service blocks tax invoices, this often means immediate financial problems: the company loses the ability to claim a tax credit, partners delay payments or suspend supplies, and payment chains are disrupted. In such a situation, it is critical to respond quickly and professionally – prepare explanations, collect supporting documents, initiate dialogue with tax inspectors and, if necessary, challenge the blocking in administrative proceedings or in court.
Delays in VAT refunds. When VAT refunds are delayed or additional explanations are requested, this affects working capital and investment plans. Often such delays are based on formal grounds or on doubts by the tax authorities regarding the good faith of counterparties. PRAGNUM analyses the documents, confirms the business purpose of transactions, prepares complaints, demands consideration within the framework of administrative procedures, and also prepares litigation steps to expedite the return of funds.
Non-standard requests from tax authorities. Sometimes the State Tax Service sends requests that go beyond its lawful powers or contain wording that may lead to the transaction being recognised as fictitious. In such cases, a precise legal position, an evidence-based dossier and a carefully balanced interaction strategy are required in order to avoid escalation into administrative or criminal proceedings.
Suspicions regarding “risky” counterparties. If a counterparty is included in the list of risky entities or the tax authorities doubt the reality of business transactions, the consequence may be the refusal of a tax credit or even the recognition of the transaction as fictitious. In such cases, we prepare an evidentiary base confirming the reality of transactions and their economic feasibility, and we also develop a plan for the lawful substitution of risky links in the chain.
Complex supply and sub-supply chains. Multi-level contracts, sub-supplies, redistribution of risks – all this creates a field for tax disputes. We analyse the structure of the arrangements, identify legally significant facts, prepare corrective documents or adjust processes to minimise risk.
Clients preparing for major transactions (M&A, IPO, raising investment). Before significant transactions, a tax audit by lawyers is required – not only an accounting check, but a legal review of tax positions, warranties, historical risks and possible liabilities that may arise after closing.
Situations involving personal risk for managers. Sometimes tax claims escalate into the sphere of personal liability or even criminal prosecution of officers. PRAGNUM develops mechanisms to minimise such risks, defends management in administrative and criminal proceedings, and builds a defence line that combines procedural and substantive arguments.
The need for long-term legal support. Some companies are interested in a systemic partnership, where audits and monitoring are transformed into an ongoing service: quarterly risk reviews, policy updates, preparation for inspections and constant legal support in disputes.

All of the above cases are classic risk zones for businesses in Kyiv, where even the slightest mistake can lead to significant losses. That is why PRAGNUM forms individual teams and strategies specifically for such tasks.

Blocking of tax invoices in Kyiv – legal advice

What do we offer?

PRAGNUM Law Firm provides a comprehensive and practically oriented set of services for resolving specific tax issues for businesses in Kyiv. Each service is adapted to the client’s business model and includes procedural support as well as tactical and strategic actions.

1.Unblocking tax invoices: situation audit, preparation of explanations, representation before the Kyiv office of the State Tax Service, challenging decisions.

verification of the grounds for blocking;
preparation of detailed explanations with economic and legal argumentation;
submission of complaints within the framework of the State Tax Service’s administrative procedures and initiation of court challenges where administrative interaction proves ineffective;
parallel preventive measures with counterparties to stabilise supply chains.

2. Support in VAT refunds: legal analysis of documents, communication with the tax authorities, preparation of complaints, defence in court.

thorough analysis of the document packages submitted for VAT refunds;
identification of “weak spots” in the documents and their remediation (internal memos, additional accounting preparation);
a well-founded litigation position regarding unlawful refusals to refund;
work with financial and tax experts to prepare opinions and calculations.

3. Tax legal support: strategic advice for businesses in non-standard situations, preparation for inspections.

Preparing a 'Frequently Asked Questions' document for employees on interacting with the tax authorities.
advice on building safe supply chains and optimising business processes, taking into account tax risks.

4. Tax lawyer services for businesses: comprehensive support in transactions and inspections, advice for top management, protection of interests in court and before the State Tax Service.

legal support in contract negotiations and transaction structuring;
representation in administrative procedures before the State Tax Service;
preparation of appeals and cassation complaints;
support in criminal proceedings where matters have taken on criminal-law aspects.

5. Compliance and risk audit: diagnosis of weak points, development of a risk minimisation strategy, support in implementing new business processes.

creation of internal policies for confirming the business purpose of transactions;
development of procedures for counterparty checks (KYC/AML elements with a tax focus);
preparation of contracts and document-flow procedures that minimise formal risks;
training of key employees and regular reviews of the processes implemented.

Each service is provided with a deep understanding of the risks specific to Kyiv as a centre of economic relations: regional business chains and international interests often intersect here, and there is heightened attention from supervisory authorities.

VAT refunds in Kyiv – professional legal assistance

Stages of our work.

PRAGNUM works according to a transparent, step-by-step methodology that allows the client to clearly see progress, risks and the final result.

1.Initial audit and consultation: examination of the problem, analysis of documents, assessment of the chances of a positive outcome.

an operational “hotline” for preliminary assessment: we set timeframes, identify key documents and initial steps;
collection of initial materials: contracts, acts, tax returns, bank statements, correspondence with counterparties and the State Tax Service;
a brief risk screening and identification of likely scenarios (administrative resolution, litigation, negotiations with counterparties).

Development of a resolution strategy: determination of scenarios, preparation of legal positions, agreeing actions with the client.

formation of several scenarios for how events may unfold, with assessment of probabilities and consequences;
a detailed legal position with references to the provisions of the Tax Code of Ukraine, court practice and precedents;
a plan of documentary steps: which additional documents or clarifications need to be collected;
agreeing a road map with the client, including allocation of responsibilities and timelines.

Implementation of the strategy: support in correspondence, submission of complaints, participation in negotiations, representation in court or before the tax authorities.

preparation and submission of administrative complaints to the State Tax Service;
where necessary, filing of claims with the administrative court, supported by argumentation and evidentiary materials;
active negotiations with the State Tax Service and counterparties to reach compromise solutions that minimise the client’s costs;
where necessary – initiation of independent expert examinations and involvement of financial analysts.

Post-resolution support: monitoring the situation, recommendations on future actions, strategic advice.

monitoring the implementation of decisions (lifting of blocks, VAT refunds, lifting of seizures);
preparation of preventive measures to avoid recurrence of risks;
development and implementation of policies and procedures that minimise tax risks in the long term.

Each stage is accompanied by detailed reports and an action plan so that the company’s management can take decisions based on well-balanced information.

Tax lawyer services for businesses in Kyiv

Why choose PRAGNUM specifically for Kyiv?

The choice of a legal partner for specific tax issues is a choice not only of consulting, but also of a strategy for the survival and development of the business. For companies in Kyiv, it is important to have an adviser who understands both the local context and the global realities of taxation. PRAGNUM Law Firm has several significant advantages in this area.

Deep expertise in resolving non-standard, specific tax issues precisely for businesses in Kyiv. Our team has practical experience in handling blocked tax invoices, VAT refunds, disputes concerning transfer pricing and complex international transactions. We combine knowledge of the Tax Code of Ukraine, court practice and real business logic.
A premium level of service, strategic approach, in-depth audit, individual solutions. PRAGNUM does not provide “standard” advice: each legal position is based on in-depth analysis, expert opinions and takes into account the client’s business interests.
Full confidentiality and personalised support, focusing on building long-term partnerships with our clients. We operate in accordance with the standards of legal professional privilege and corporate security, and we conclude non-disclosure agreements and use secure communication channels where necessary.
The reputation of a reliable legal adviser for business. Our clients are owners, investors, and CFOs who choose PRAGNUM for results rather than for price. We demonstrate real cases of risk reduction, successful challenges of tax authority decisions and stabilisation of companies’ finances.
A team-based approach and resource base. To solve complex issues, we involve expert accountants, financial analysts, IT specialists (for the recovery of electronic evidence), as well as external transfer pricing experts – all to ensure that the client’s protection is comprehensive and of the highest quality.

Tax legal support in Kyiv – legal representation

Frequently asked questions.

How can issues with blocked tax invoices in Kyiv be resolved?

Only through an in-depth audit, professional preparation of documents and competent defence before the tax authorities and in court.

How can VAT refunds be obtained quickly?

Through qualified support from a tax lawyer: correct preparation of documents, professional communication with the State Tax Service, challenging delays and unlawful refusals.