Larysa Antoshchuk

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Larysa Antoshchuk

Counsel

practice areas

Larysa heads tax disputes group and focuses on assisting companies during the tax audit process, as well as in pre-trial appeals and court proceedings related to tax disputes.

Since 2006, Larysa has been consulting both international and local companies, as well as individuals, on various tax-related issues from perspective of tax dispute resolution, including the specifics of applying Withholding Tax, Corporate Profit Tax, VAT, and employment taxes.

Recently, Larysa has also successfully handled transfer pricing tax disputes, application of international double tax treaties in Ukraine and related tax incentives, conducted legal and tax due diligence, and defended companies' management in cases involving economic crimes.

Recognition:

named a rising star in tax controversy, World Tax Review 2024
named among the leading lawyers in tax litigation, Ukrainian Law Firms 2024. A Handbook for Foreign Clients
recognized as the best tax dispute resolution lawyer, LigaZakon Awards 2020

Education:

Ostroh Academy National University, State University of Finances and International Trade, Master of Laws (International Law), 2008
Admitted in Ukraine, 2011

Languages:

English, Ukrainian, Polish

Membership and activities:

Aspen Institute Kyiv
Ukrainian Bar Association
Chamber of the Tax Advisers

Representative experience:

representing a national fuel supplier in a dispute over transfer pricing issues arising from the results of a tax audit of the company's transactions over several years, with the subsequent additional accrual of income tax exceeding UAH 80 million
representing a leading global construction company in a tax dispute regarding the additional accrual of UAH 640 million of corporate income tax related to the application of the investment property valuation model, and UAH 110 million concerning the discounting of a long-term loan
representing an international optical manufacturer in a dispute with tax authority over the taxation of royalties for the use of a trademark by stores selling goods and the taxation of a lease transaction

representing a national fuel supplier in a dispute over transfer pricing issues arising from the results of a tax audit of the company's transactions over several years, with the subsequent additional accrual of income tax exceeding UAH 80 million
representing a leading global construction company in a tax dispute regarding the additional accrual of UAH 640 million of corporate income tax related to the application of the investment property valuation model, and UAH 110 million concerning the discounting of a long-term loan
representing an international optical manufacturer in a dispute with tax authority over the taxation of royalties for the use of a trademark by stores selling goods and the taxation of a lease transaction
representing a global producer of solar electrical energy group of companies in a seria of disputes over the accrual of depreciation and the classification of solar power plant components into specific groups of fixed assets, resulting in an additional accrual of more than of UAH 100 million of corporate income tax liability
representing a leading national broadcasting group of companies in a tax dispute regarding the application of a discounted non-resident income tax rate on royalty payments to a non-resident distributor (Principal Purpose Test)
representing a company in an international food production group in a dispute over the additional accrual of more than of UAH 130 million based on the results of applying calculations for the discounting of long-term liabilities under loan agreements obtained from the parent company
representing a number of large enterprises from Ukrainian and international business groups, Representative offices in disputes over WHT, VAT consequences of transactions with goods suppliers (validity of transactions), as well as issues related to the inclusion of companies on the list of high-risk taxpayers, related refusals to register tax invoices, and the application of penalties for late registration of tax invoices
representing officials from several Ukrainian companies in cases related to administrative responsibility based on the results of tax audits
representing Ukrainian and international business groups in criminal cases initiated by the Security Service of Ukraine and the Economic Security Bureau concerning issues with an economic component