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Dmytro Harnyi

Author

Dmytro Harnyi

Head of the Center, lawyer, tax expert

Head of the Kyiv Center for Business Support and Development. A lawyer with more than 20 years of experience advising Ukrainian businesses—from microbusinesses and sole proprietorships (FOPs) to medium-sized companies and industry associations. He specializes in defending businesses during tax audits, appealing the actions of regulatory authorities, and the practical application of tax law. A regular contributor to numerous business and professional media outlets since 2004, he explains complex regulations in simple language and provides actionable frameworks for owners. He speaks at industry press conferences, forums, and seminars on the legal defense of business, audits by the State Tax Service (STS), and law enforcement agencies. He has experience protecting the interests of industry communities, particularly the tourism industry, transportation companies, internet providers, and small retail businesses, in their dialogue with the state. Professional creed: "Anticipate risks, don't fight the consequences."

Articles by this author

Lawful tax saving or evasion: where the line runs

Where the line runs between lawful tax optimisation and evasion: the business-purpose test, splitting into private entrepreneurs, Art. 212 of the Criminal Code, Supreme Court practice and international cases. Analysis by KCPRB.

July 21, 202613 min read

Debt-to-Equity Swap: How to Safely Structure It for a Ukrainian LLC (ТОВ)

The D2E swap mechanism allows an LLC (ТОВ) to “settle” its debt to a participant by increasing its charter capital. We break it down step by step: corporate law, personal income tax (ПДФО) and the military levy, controlled foreign companies (КІК), the position of the State Tax Service (ДПС), court practice, and typical mistakes.

July 4, 20269 min read

Risks of Selling Through Marketplaces: Legal and Tax Aspects

Law No. 15111-d eliminates the asymmetry between real online turnover and what the State Tax Service (DPS) sees. We break down the timeline of changes, the Payoneer/Wise trap at 13 p.p., the risks for individual entrepreneurs (FOPs), and the roadmap for preparing for 2027.

June 11, 202614 min read