APRIL 30, 2026 • 13:00 (Kyiv time)

Taxation of non-residents’ passive income

Current approaches and practical aspects

Why should you join?

Key topics of the conference:

Paying out income safely

How can dividends, interest, and royalties be paid in compliance with legal requirements while minimizing tax risks?

Analyzing current administrative and court practice

What approaches have been developed in administrative and judicial practice regarding the application of withholding tax?

Preventing abuse

What approaches are used to address treaty shopping, intermediary companies, and the concept of economic substance?

Applying specific rules correctly

How are the Principal Purpose Test and Limitation on Benefits applied?

Speakers

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Raisa Khanova

The Judge of the Administrative Cassation Court within the Supreme Court, the Secretary of the Judicial Chamber for Taxes, Fees and Other Mandatory Payments of the Administrative Cassation Court within the Supreme Court, PhD in Law, Honored Lawyer of Ukraine

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Yuliia Katsan

Director of the Transfer Pricing Department of the State Tax Service of Ukraine

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Oksana Muzyka-Stefanchuk

Corresponding Member of the National Academy of Legal Sciences of Ukraine, Doctor of Law, Professor, Head of the Financial Law Department at the Educational and Scientific Institute of Law of Taras Shevchenko National University of Kyiv

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Roman Krokhmal

Tax Law Expert, CEO of ADO TAX

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Serhii Broyakov

PhD, Lecturer at the Tax Law Department at Yaroslav Mudryi National Law University, Head of Tax Practice at Bona Lex, Member of the Advisory Council on the Regulation of Virtual Assets, organized by the National Securities and Stock Market Commission

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Dmytro Kobylnik

Doctor of Law, Professor, Head of the Tax Law Department at Yaroslav Mudryi National Law University

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Stéphane BONICHOT

Attorney at the Paris Bar, Partner at BRIARD BONICHOT & Associés

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François-Henri BRIARD

Attorney at the Conseil d’État and the Court of Cassation, Partner at BRIARD BONICHOT & Associés

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Moderator

Yevhen Smychok

Doctor of Law, Associate Professor of the Tax Law Department at Yaroslav Mudryi National Law University, CEO of Bona Lex, Member of the Scientific Advisory Council at the Supreme Court

Conference Topics

“Treaty Shopping”: How Tax Authorities Identify Intermediary Companies

Economic Substance criterion – Proving Substance

Beneficial Owner Of Income: Current Case Law

Methods For Limiting Benefits Under Double Taxation Avoidance Conventions:
Principal Purpose Test, Limitation on Benefits

Changes in Approaches to the Taxation of “Flow-Through” Dividends (Application of para. 170.131 of the Tax Code of Ukraine)

Partners

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Yaroslav Mudryi National Law University

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Educational and Scientific Institute of Law of Taras Shevchenko National University of Kyiv

Partners

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Yaroslav Mudryi National Law University

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Educational and Scientific Institute of Law of Taras Shevchenko National University of Kyiv

For any inquiries, please contact us at moc.xatoda%40olleh