A business strategy session for owners with Maksym Stepanenko: we review your international structure, entry into new markets, company and owner taxes, and hand you a step-by-step action plan.

Since 2012 · 50+ jurisdictions · action plan after the session · turnkey implementation by one team

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In brief

  • The Crystal Tax strategy session is a paid format for a business owner and their partners. It is led by Maksym Stepanenko, managing partner of Crystal Tax, who has been building international structures in 50+ jurisdictions since 2012. Facilitating a management team on mission and OKRs is a different format, run by business coaches.
  • In the session we review the international structure of the business (which companies, where, who owns what, whether a holding company is needed), entry into the EU, UK, US, UAE and other markets, company taxes and the owner's personal taxes, banks and payments.
  • Afterwards you receive an action plan: what to do, in what order, which documents and registrations are needed, which risks to account for. The same Crystal Tax team can implement the plan turnkey: companies, bank accounts, accounting, Ukrainian CFC reporting, relocation.
  • For an owner who is a Ukrainian tax resident, we look at the Ukrainian CFC (controlled foreign company) rules separately in the session. Under Ukrainian law, a Ukrainian resident becomes a controlling person with a stake above 50 percent, or above 10 percent when Ukrainian residents together own 50 percent or more, or with actual control over the company, and the CFC profit is added to their income unless one of the exemption conditions is met. The CFC report is filed together with the annual tax return, by 1 May for individuals.
  • You can start with a free 10-minute introduction or a 30-minute consultation for €100 on one question. We agree the format, length and participants of the strategy session to fit your task and propose an agenda within one business day of your request.

Your situation

Pick the situation closest to yours: a short note on what we cover in the session and where we start.

My business operates in Ukraine and I want EU clients

We compare two or three EU countries for the company: corporate tax, VAT, bank, director and substance requirements. We calculate the owner's taxes in Ukraine, including the Ukrainian CFC rules, and set out the order of steps.

Example. The owner of an IT company from Dnipro wants to sign contracts with German clients through a European company. In the session we choose the country, allocate contracts and staff and decide what to do before the first invoice to a client.

Discuss this case →
I moved to Europe, but the company and accounts stayed in Ukraine

We review tax residency under the tests of the Tax Code of Ukraine and of the new country, and what happens to the Ukrainian company and personal accounts. The plan shows what to change right away and what to change after your residency changes.

Example. The owner of a trading company lives in Poland with his family while the business runs in Kyiv. We determine where his centre of vital interests is, how he should receive income and what he must file in each country.

Discuss this case →
Companies in several countries, I want clear ownership

We map the current ownership chain down to individuals and find redundant links and risks for banks and tax authorities. We propose a target structure, with a holding company if needed, and the order of transitions.

Example. An entrepreneur has three companies in different countries, set up at different times for different projects. We bring them into a clear structure and plan which companies to close and which to transfer to a holding.

Discuss this case →
We are entering the US or UK market

We review the company form, federal and state taxes or UK corporation tax, the bank and payment services. Separately, we work out how profit will reach the owner.

Example. A home goods manufacturer is launching sales on a US marketplace. In the session we choose the company form, the state, the bank and the settlement scheme with the production in Ukraine.

Discuss this case →
Preparing for an investor or a sale of the business

We check how the structure looks to an investor or buyer: who owns the shares and the intellectual property, where the contracts sit, what reporting exists. The plan shows what to put in order before negotiations.

Example. The founders of a SaaS product are in talks with a fund. We decide in which country the parent company should be, who owns the code and which documents the investor will ask for.

Discuss this case →
Partners live in different countries and need to agree on shares

We invite all partners to the session and review shares, management, partner exit and each partner's taxes in their own country. The agreements are then fixed in a shareholders agreement.

Example. Three partners live in Ukraine, Spain and the UAE and are launching a joint project. We choose the company's country, split the roles and record what goes into the shareholders agreement.

Discuss this case →

What we cover in a strategy session

In a strategy session we cover six topics that shape the international structure of a business: ownership, markets, taxes, banks, people and the order of steps. We agree the agenda, depth and participants before the meeting, so the time goes to your decisions.

Meeting room table with a laptop, a notebook with a hand-drawn diagram of linked blocks and a world map in the background, preparing for a strategy session
Strategy session: business structure, markets and taxes on one chart

Structure and ownership

Which companies you need, in which countries, who owns them and in what shares, whether a holding company is needed. We draw the ownership chain down to individuals, the way a bank and a tax authority see it. We check where each company is actually managed and whether that creates a taxable presence in another country. If there are several partners, we note what to fix in writing, for example in a shareholders agreement.

New markets

The EU, the UK, the US, the UAE and other countries: where to open a company or a branch for your clients, which registrations are needed for sales and hiring, what the bank and the local tax authority require. We also check whether you need a local director, an office or staff for the company to pass bank and tax checks, and how many reporting obligations appear in the first year.

Company and owner taxes

We compare corporate tax in candidate countries, taxes on dividends and salaries, and the owner's personal taxes. For Ukrainian tax residents we separately check the Ukrainian CFC (controlled foreign company) rules, tax residency and the conditions for exempting CFC profit from tax. If there are several owners living in different countries, we calculate each one's taxes, because the same structure gives partners different results.

Banks and payments

Where the company's and the owner's accounts will be, which payment services fit the business model, which source-of-funds documents will be needed. The bank decides whether to open an account; our job is to pick realistic options and prepare the application package.

People and relocation

Where the owner and key staff will live, whether a residence permit is needed, and how this affects tax residency and where the company is actually managed.

Risks and order of steps

What could stop the plan: bank requirements, Ukrainian CFC reporting, double taxation, government processing times. For each risk we set an action and its place in the sequence of steps.

Strategy session result: an action plan

The result of the strategy session is an action plan for the owner: which steps to take, in what order, in which jurisdictions, with which documents and who is responsible for what.

  • Target structure. Companies, countries, shares, a holding company if needed, and the ownership chain down to individuals.
  • Chosen jurisdictions. Why each country was chosen, which taxes and obligations arise for the company and the owner.
  • Order of steps. What to do first, what comes next, which actions depend on each other.
  • Documents and registrations. Company registration, tax numbers, VAT, bank accounts, Ukrainian CFC notices and reports, relocation documents.
  • Who does what. Tasks for the owner, partners, accountant and Crystal Tax.
  • Risks. What to consider with banks, tax authorities and partners, and how to reduce each risk.
  • Open questions. What to clarify with the accountant, bank or partners before the next step, and by what date.

We write the plan for the owner: short, step by step, with clear decisions. You can hand it to partners, a CFO or an investor so everyone works from the same structure.

You can implement the plan yourself or hand it to us turnkey: company registration abroad, bank accounts, accounting, Ukrainian CFC reporting and relocation are handled by one team. The plan is then carried out by the same team that helped prepare it.

Describe your business, countries and goal, and on a free 10-minute call we will tell you whether you need a strategy session and what its agenda would include.

30-minute consultation or strategy session: which to choose

A 30-minute consultation suits one scenario or question; a strategy session covers the whole business structure and ends with a written action plan.

FormatWhat it is forDepthResult
Introduction, 10 minutes, freeUnderstand whether you need a structure now and where to startThe task in broad termsDirection and next step
Consultation, 30 minutes, €100A short paid review of one scenario or questionJurisdiction and structure options, risks, answers to your questionsA clear view of the options for one scenario
Strategy sessionThe whole business structure: ownership, markets, company and owner taxes, banks, relocationSet to the task; agenda and participants agreed in advanceAction plan: steps, order, jurisdictions, documents, risks

If you are unsure, start with the free 10 minutes: from your description we will tell you which format is enough. How our work runs from the first question to a finished structure is described on the page how we work.

Timeline: from request to plan

We propose the agenda and format of the strategy session within one business day of your request, and agree the meeting date with you and your partners.

Usually, in our experience, the time until the session depends on preparation: how quickly the information on companies, owners, turnover and plans is collected. The fuller the questionnaire, the more precise the agenda and the fewer questions are left for later. We prepare the action plan after the session and name its preparation time when we agree the agenda. Timing depends on the case, its details, the work of the authorities and force majeure.

Implementation runs on its own schedule: company registration, account opening and relocation depend on registries, banks and immigration services. The official deadline of an authority covers only the review of complete documents, so the plan lists the stages and what each of them depends on. If you have an external deadline, such as investor talks, the start of a contract or a family move, mention it in your request: we will build the agenda and the order of steps around that date.

What the cost of a strategy session depends on

We price each strategy session to the task: the cost depends on the number of countries and companies, the complexity of the current structure and the depth of the plan.

  • how many countries and companies we review, and whether there is a holding company;
  • how complex the current structure is and how many links it has;
  • how many partners there are and in which countries they are tax resident;
  • whether tax calculations and a comparison of several options are needed;
  • how detailed the written plan should be;
  • which languages the work and documents are in.

The only published price is the 30-minute consultation at €100; the 10-minute introduction is free. We quote a session within one business day of a short description of your task. The quote lists the agenda topics, the participants and what the written plan will include, so you see the scope of work in advance. Implementation of the plan is quoted separately, per country and service. We work under a contract.

Why owners trust us with their strategy

A plan for an international structure makes sense only if it can be carried out, and owners trust us with it for five reasons:

In practice since 2012

For fourteen years we have been building international structures, registering companies, opening accounts and handling tax matters in 50+ jurisdictions. We know the requirements of registrars, banks and tax authorities from our own cases.

We implement the plan turnkey

Registrations, bank applications, tax registrations and reporting under the plan are handled by Crystal Tax lawyers and accountants together with partners in each country. We handle correspondence with authorities and banks; you provide documents and decisions.

We see the matter through

We resolve registrar and tax authority comments and bank questions on our work at no extra charge.

One team for the whole structure

Structure, companies, accounts, accounting, taxes and Ukrainian CFC matters are handled by one team, so you need no separate contractor for each country.

Contract and confidentiality

Scope of work, timing and confidentiality are set out in the contract. We disclose data about you, your partners and companies only to the extent the procedure requires.

How a strategy session works, step by step

A strategy session has six steps, from request to implementation. We need information about the business and your decisions; we take care of the preparation and the plan.

Flowchart of the strategy session: request, questionnaire and documents, agenda, session, action plan, turnkey implementation
How a strategy session with Crystal Tax works
  1. Request. You briefly describe the business, the countries and the goal. You can start with a free 10-minute consultation.
  2. Questionnaire and documents. You send the ownership chart, countries and turnover of the companies, the owners' tax residency and market plans.
  3. Agenda. We propose topics, depth, participants and format, and agree the date.
  4. Session. We review structure, markets, taxes, banks and relocation, compare options and make decisions.
  5. Action plan. We record the steps, order, jurisdictions, documents, responsible people and risks.
  6. Turnkey implementation. At your decision we register companies, prepare bank applications, set up accounting and Ukrainian CFC reporting, and support relocation.

What to prepare for a strategy session

For the session it is enough to gather information about the current business and your goals: we clarify the rest through the questionnaire.

  • the ownership chart: companies, countries, shares, who the ultimate owner is;
  • approximate turnover and profit per company, main clients and sales countries;
  • where the owners and partners live, where they are tax resident, whether they hold a residence permit or temporary protection;
  • which bank accounts and payment services you already have;
  • whether Ukrainian CFC notices and reports have been filed, if the owner is a Ukrainian tax resident;
  • plans for the coming years: new markets, an investor, a sale, relocation;
  • the questions you want answered after the session.

If some information is missing for now, note it in the questionnaire: we can cover part of the questions at the meeting itself. We use the data only to prepare the session; confidentiality terms are set out in the contract.

Owners from Ukraine in 2026: Ukrainian CFC rules, tax residency, data exchange

If the owner of a foreign company is a Ukrainian tax resident, they are subject to the controlled foreign company rules of Article 39-2 of the Tax Code of Ukraine, and we account for these rules in any plan.

  • Who is a controlling person. Under Ukrainian law, a Ukrainian resident who holds more than 50 percent of a foreign company, or more than 10 percent if Ukrainian residents together own 50 percent or more, or who actually controls the company.
  • What is taxed. The adjusted CFC profit, in proportion to the stake, is included in the owner's annual taxable income in Ukraine.
  • Exemption. The profit is excluded from income if Ukraine has a double tax treaty or a tax information exchange agreement with the country and one of the conditions is met: the company actually pays corporate tax at an effective rate at least equal to the basic Ukrainian rate of 18 percent or no more than five percentage points below it, or passive income makes up no more than 50 percent. Profit is also exempt if the total income of all CFCs of one person does not exceed the equivalent of 2 million euros at the end of the reporting period according to the financial statements.
  • Reporting. A notice of acquiring or disposing of a stake is filed within 60 days. The CFC report is filed together with the annual tax return, by 1 May of the following year for individuals, with the company's certified financial statements.
  • Martial law. CFC penalties do not apply provided all obligations are fulfilled within six months after martial law ends or is lifted. The obligations themselves remain.
  • Rates for individuals. Personal income tax of 18 percent and military levy of 5 percent.
  • Tax residency. An individual is a Ukrainian tax resident if their place of residence is in Ukraine. If they also have a home abroad, the tests are applied in turn: permanent home, centre of vital interests and presence in Ukraine for at least 183 days a year.
  • Data exchange. Ukraine takes part in the automatic exchange of financial account information under the CRS standard. According to the OECD, Ukraine planned its first exchange for September 2024.
  • Temporary protection in the EU. We check its term and its effect on tax residency as of the date you contact us.

We prepare the notices and reports as part of our Ukrainian CFC reporting service.

Corporate tax in popular jurisdictions in 2026

Corporate tax is one of the figures we use to compare countries in the session, together with the owner's taxes, bank requirements and the Ukrainian CFC rules.

CountryCorporate tax rateConditions
United Kingdom25 percent, 19 percent for small profits19 percent for profits up to 50,000 pounds, 25 percent above 250,000 pounds, marginal relief in between. Financial year from 1 April 2026
UAE0 and 9 percent0 percent on taxable income up to 375,000 dirhams, 9 percent on the amount above it
Estonia22/78Tax is paid on profit distribution: 22/78 of the net payout, that is 22 percent of the gross amount. The reduced 14/86 rate for regularly paid dividends was abolished from 1 January 2025
Poland19 percent, reduced 9 percent9 percent for small taxpayers and companies in their first year of activity with annual revenue up to 2 million euros
United States21 percentFederal corporate income tax, excluding state taxes

For comparison, the basic corporate tax rate in Ukraine is 18 percent. The 15 percent global minimum tax under the OECD model rules applies to multinational groups with annual consolidated revenue of 750 million euros or more. We check the rate for your country as of the session date.

How to book a strategy session

Write two or three sentences on what the business does, in which countries the companies and owners are, and what decision you expect. Within one business day we will propose the agenda, format and participants of the strategy session and quote the cost. If you would like to get acquainted first, book the free 10 minutes. For a short review of one question, a 30-minute consultation for €100 is enough.

How we help after the session

Sources

Tax Code of Ukraine, Articles 14.1.213, 39-2, 49.18, 136, 167, Subsection 10 of Section XX, version of 17.09.2026; OECD: MCAA CRS signatories and intended first exchange date; GOV.UK: Rates and allowances, Corporation Tax; UAE Ministry of Finance: Federal Decree-Law No. 47 of 2022, Corporate Tax; UAE Ministry of Finance: Cabinet Decision No. 116 of 2022; UAE Ministry of Finance: Top-up Tax; Estonian Tax and Customs Board: tax rates 2026; Podatki.gov.pl: CIT, stawki i limity; 26 U.S. Code § 11, tax imposed on corporations; IRS: Instructions for Form 1120. Reviewed and updated on 27.09.2026.

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Frequently asked questions

What is a business strategy session at Crystal Tax?
How does this strategy session differ from a team strategy session with a facilitator?
How much does a strategy session cost?
What do I get after the session?
How long does a strategy session last and where is it held?
When is a 30-minute consultation enough?
Can I attend the session with my partners?
I am a Ukrainian tax resident. What will we cover on the Ukrainian CFC rules?
How do I know whether I remain a Ukrainian tax resident after moving?
Does the 15 percent global minimum tax apply to me?
Who implements the plan after the session?
How confidential is the information about my business?
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Maksym Stepanenko

Maksym Stepanenko

Managing Partner, Crystal Tax

International client projects since 2012: company structures, tax, immigration, DUNS and NCAGE. 50+ jurisdictions.

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