Tax planning

International business tax planning works best when the company, agreements and payments are built around real profit. An offshore company can perform a trading, service, holding or investment function, while a European company can complement the structure with local payment details and business infrastructure. The owner defines in advance where income is generated, how the business is financed and where profit will be directed after the transaction. The international structure then becomes a clear commercial instrument that can be calculated before the companies are registered.

What a workable international structure is

An international business structure is a sequence of real transactions between companies, customers, suppliers and banks. Its purpose is to direct goods, services, financing and profit through the appropriate legal entities. Where each company performs a clear function, the owner receives a manageable structure and can compare its economics with alternative models.

For example, a trading company buys goods and sells them to customers, a service company provides services to the group, and a holding company owns shares and accumulates investment capital. One business can use all three functions, each with a separate commercial purpose and clear payments.

Trading structure

International trade begins with the supplier, buyer, logistics and margin. The company enters into agreements, pays for purchases, organises delivery and receives revenue. The country of incorporation is selected with counterparties, currencies, the customs model and banking options in mind.

An operating account is particularly important for trade. The bank should support the required countries and currencies, and fees should match transaction frequency. Where the business sells through marketplaces or accepts card payments online, acquiring, electronic wallets and multi-currency corporate accounts are considered as well.

Service structure

Consulting, software development, marketing, engineering and professional services can be provided through a separate service company. It contracts with clients, pays the team and earns profit from its own services. For the bank, this model is described through the website, project portfolio, agreements and customer geography.

Where the service company works within a group, its remuneration is calculated around the functions performed and costs incurred. This allows the owner to see the real cost of management, technical and commercial functions and plan the profit of group companies accurately.

Holding structure

A holding company brings together interests in subsidiaries, receives dividends and finances new projects. It is convenient for a business operating in several countries or planning acquisitions and disposals. A separate holding level allows the owner to manage capital independently of daily operating payments.

When selecting the holding jurisdiction, double-tax treaties, corporate law, administration cost and banking infrastructure are assessed. For EU companies, intra-group payment rules and the relevant European directives are also considered.

Investment structure

For acquiring property, securities or an interest in a business, a separate investment company can be convenient. Its capital, bank account and documents are connected with the specific assets. This simplifies the income and expense calculation and a future disposal of the project.

Where there are several investors, a fund or partnership structure can be used. In Ukraine, infrastructure of collective investment institutions and asset management companies is available for a range of projects. An international investor can combine such a local structure with a holding company or separate investment company.

Intra-group financing

Capital can be provided to subsidiaries through an equity contribution or a loan. The first suits long-term ownership; the second suits a project with a defined repayment period. The financial model shows how much each company requires and when capital returns to the holding level.

Interest, terms and documents between related companies are set on commercial principles. This matters both for calculating the project return and for explaining payments clearly to the bank.

Payment scheme

The legal structure becomes operational once accounts are opened. Each company has a main flow: customer receipts, purchases, contractor payments, dividends or investments. A bank or European payment institution (EMI) is then selected for that function.

Group companies can have main and reserve accounts. This allows operating and investment payments to be separated and different financial institutions to be used for different currencies and countries.

Financial monitoring as part of transaction preparation

In 2026, Ukrainian banks operate under Law No. 361-IX and their own risk-based procedures. Foreign banks also analyse the customer and the commercial purpose of transactions under their own rules. For an entrepreneur, this means a high-quality document package should be prepared at the same time as the agreement.

For an international transaction, it is useful to have the contract, invoice, description of goods or services, supply or performance documents and a clear payment purpose. This preparation makes the work of both the accounting team and the banks easier.

What changed in 2026

In 2026, international businesses increasingly design the tax and banking side as one model. The company is selected together with the account, agreements together with payments, and the investment exit before the asset is acquired. This makes profit and administration costs easier to calculate accurately.

For Ukraine, Law No. 361-IX in the version dated 26 June 2026 remains the current basis of financial monitoring, while the 2025 typology studies of the State Financial Monitoring Service are used by the financial market as current analytical material. For a company owner, this is primarily an instrument for preparing international payments well.