On 25 June, the Solar Energy Association of Ukraine (SEAU) held a closed meeting of its Legal Committee, dedicated to the latest developments in international taxation and cross-border payments to non-residents.
The meeting was moderated by Ivan Balytsky, Head of the SEAU Legal Committee.
The keynote speaker was Natalia Kurilenko, Head of Tax Practice at the Sokolovskyi & Partners Law Firm, auditor, and attorney-at-law. She provided participants with a comprehensive overview of the latest approaches adopted by the tax authorities to monitor international payments and shared practical recommendations on minimizing tax risks.
The discussion focused on regulatory changes that are already having a significant impact on Ukrainian companies making dividend, interest, and royalty payments to non-residents, particularly in Cyprus, the United Kingdom, Austria, and the Netherlands.
During her presentation, Ms. Kurilenko emphasized that 2026 has become a turning point in international taxation, as the verification of large cross-border payments made by Ukrainian companies has been identified as one of the key priorities for the Ukrainian tax authorities in the coming years. Particular attention will be paid to verifying the beneficial owner status of the income recipient, the existence of sufficient economic substance, and the application of the Principal Purpose Test (PPT) under the Multilateral Instrument (MLI).
A separate part of the meeting was devoted to the conditions under which companies may apply reduced withholding tax rates under international double taxation treaties. Participants examined the practical criteria for confirming beneficial ownership, the documentary requirements for demonstrating the economic substance of foreign companies, and the specific features of working with the most commonly used European jurisdictions.
Considerable attention was also given to current tax audit practices. In particular, the speaker analyzed the main risk factors and triggers that are likely to attract the attention of the tax authorities.
In addition, participants received practical guidance on preparing documentation to support the application of international tax treaties, compiling a comprehensive Defense File, reviewing ownership structures and the economic substance of foreign entities, and minimizing the risk of additional tax assessments at the standard 15% withholding tax rate, as well as potential financial penalties.
Following the presentation, participants took part in a traditional Q&A session, where they discussed their own practical cases related to international payment structures, corporate ownership arrangements, and the application of international tax treaties.
SEAU continues to organize meetings of its specialized committees, providing Association members with a professional platform to discuss the latest legislative developments, exchange practical experience, and receive expert guidance on conducting business in Ukraine’s energy sector.