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ANDRII
LYTVYNENKO
International Taxation Manager

Reliable, experienced International EDUCATION
taxation consultant with outstanding
professional skills and relationship- Yaroslav the Wise National Law University
building strengths. Dedicated to providing 2013-09 — 2017-06
comprehensive service and constant self- Bachelor’s Degree: Law
improvement. In-depth understanding of
international taxation principles and Yaroslav the Wise National Law University
2017-09 — 2019-02
provision of legal services.
Master’s Degree: Law

CONTACT INFORMATION
WORK HISTORY
PHONE:
[открыть контакты](см. выше в блоке «контактная информация») Tax Manager
PwC Ukraine, Kyiv, Ukraine
2025-01 — Current
E-MAIL:
[открыть контакты](см. выше в блоке «контактная информация»)
• Performance of functions outlined in “Senior Associate” section at PwC
Ukraine below.
• Management of various projects related to international taxation and/ or
LANGUAGES: Ukrainian corporate profits tax and withholding tax implications which
included:
ENGLISH − Control over activities and performance of junior colleagues;
− Engagement in risk management, billing and other administrative
UKRAINIAN procedures related to the respective project;
− Communication with clients and third-party consultants with respect to
issues related to the respective project;
SOFTWARE: − Coordination of engagement of different local and cross-border teams
in complex projects.
Microsoft Word, Excel, PowerPoint,
Outlook
Senior Associate
PwC Ukraine, Kyiv, Ukraine
2022-01 — 2024-12
• Preparation of commentaries and memorandums on various international
taxation topics, namely:
− Creation of tax optimal structures for multinational groups of
companies;
− Analysis of the tax optimal jurisdictions for the set-up and functioning of
different types of companies (holding, financing, IP holding, operational
etc.);
− Analysis of the possibility to apply reduced WHT rate and/or exemption
under the bilateral double tax treaties and/or EU Directives;
− Analysis of the permanent establishment risk for Ukrainian non-resident
entities;
 − Analysis of the status of non-resident income recipient as a beneficial
owner of the respective income;
− Analysis of sufficiency of the economic substance of non-resident legal
entities for tax purposes;
− Analysis of Ukrainian WHT and compliance implications that may arise
upon direct and indirect disposal of shares of Ukrainian entity.
• Participation in audit procedures, namely, analysis and identification of
potential corporate profits tax and withholding tax risks that may arise in
Ukraine for Ukrainian and foreign legal entities.
• Preparation and pre-filling tax review of annual and quarterly corporate
profits tax returns of Ukrainian legal entities and permanent
establishments of non-resident legal entities.

Senior Associate
Crowe Mikhailenko, Kyiv, Ukraine
2021-08 — 2021-12
• Preparation of consultations on the below-mentioned matters (see “Junior
Associate” and “Associate”);
• Organization of the international taxation department work;
• Supervision and coordination of work of junior associates and associates,
delegation and review of work performed, providing feedback;
• Participation in promotional events (webinars, meetings, etc.).

Acting Senior Associate
Crowe Mikhailenko, Kyiv, Ukraine
2021-01 — 2021-07
See "Senior Associate" above.

Associate
Crowe Mikhailenko, Kyiv, Ukraine
2020-05 — 2020-12
• Preparation of consultations on the matters of international taxation, in
particular:
− Analysis of tax implications that arise in connection to payments (royalty,
interest, dividends, capital gains, service fee, payment for goods, etc.)
between residents of Ukraine and non-residents;
− Change of business-model with an aim to optimize tax burden and
conduction of the business activity;
− Evaluation of tax risks that are present in existing business-models and
analysis of ways of their minimization.
− Possibility of corporate investment fund usage for purposes of tax burden
optimization and mitigation of conduction of business activity;
− Possibility of usage of preferential tax regimes in different jurisdictions
(IP-box, participation exemption, holding company regime, etc.);
− Analysis of tax consequences that will arise in the business-model after
provisions of perspective tax legislation will enter into force (CFC rules;
business purpose test/ principal purpose test, registration of non-
residents in Ukrainian tax authority, taxation in Ukraine of the sale or
other alienation of investment assets between non-residents, etc.);
− Evaluation of the risk of non-resident’s permanent establishment
existence in Ukraine;
− Evaluation of the risk of representative office requalification into the
permanent establishment;
− Creation of business-model that is optimal from a tax perspective for
conduction of business activity in the IT, pharmaceutical, logistic,
agricultural, investment, and construction spheres;
− Evaluation of status of a non-resident who is a recipient of income as a
beneficial owner of such income for purpose of application of DTT’s
provisions;
− Analysis of tax implications that arise in case of receiving of the income
by individuals which are tax residents of Ukraine;
− Supervision over conduction of the “taxless” liquidation of the foreign
companies.
 • Search and analysis of court rulings on the matters of the international
taxation (permanent establishment, beneficial owner, etc.);
• Preparation of requests for individual tax consultation.
• Preparation of tax returns for individuals who are tax residents of Ukraine.

Junior Associate
Crowe Mikhailenko, Kyiv, Ukraine
2019-04 — 2020-04
• Assistance in preparation of consultations on the matters of international
taxation, in particular:
− Analysis of tax implications that arise in connection to payments
(royalty, interest, dividends, capital gains, service fee, payment for
goods, etc.) between residents of Ukraine and non-residents;
− Change of business-model with an aim to optimize tax burden and
conduction of the business activity;
− Evaluation of tax risks that are present in existing business-models and
analysis of ways of their minimization.
• Search and analysis of court rulings on the matters of the international
taxation (permanent establishment, beneficial owner, etc.);
• Preparation of requests for individual tax consultation.

SKILLS

New hire training 75%
Project Management 75%
High attention to detail 100%
Financial statements expertise 70%
Fast learner 100%
Preparation of consultations 90%

0.00% 25.00% 50.00% 75.00% 100.00%