Business restructuring and diagnostics of Controlled Foreign Companies – CFC

Our company is engaged in the development and structuring of business in any field of activity: IT, retail, commercial real estate market, agro-industrial etc. Eventually, it is necessary to restructure the enterprise to increase the productivity of its work. EBS is ready to offer its services for the restructuring of the client company.

The scope of activity of our company includes investment structuring, selection of the optimal tax model, development and implementation of various local and international business structures, as well as comprehensive support for investment activities and business reorganization, including the purchase and sale of securities and corporate rights, M&A transactions, incl. takeover, merger, takeover, etc.

Due to the strengthening of control by the tax authorities in Ukraine of the activities of foreign companies that are owned by Ukrainian beneficial owners, we also provide services of diagnostics of the current business structure for the presence of risks of Controlled Foreign Companies (CFCs). As a result of the diagnostics, the need to declare foreign structures in the tax authorities in Ukraine is assessed, and the potential tax burden on retained earnings that remained in foreign accounts is calculated.

Our company’s proposal is to analyze the risks of the existing international structure, as well as to provide recommendations for appropriate changes.


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