© Copyright Acquisition International 2026 - All Rights Reserved.

Article Image - Volatility and Complexity in Tax Rules
Posted 31st August 2016

Volatility and Complexity in Tax Rules

AVELLUM is best known for its expertise in transactional tax and international tax planning. The firm’s unmatched experience allows us to provide clients with the best quality services in these fields.

Mouse Scroll AnimationScroll to keep reading

Let us help promote your business to a wider following.

Volatility and Complexity in Tax Rules
Image

Volatility and Complexity in Tax Rules

Resolving Tax Controversy

AVELLUM is best known for its expertise in transactional tax and international tax planning. The firm’s unmatched experience allows us to provide clients with the best quality services in these fields. Our tax controversy practice evolved from this expertise. An in-depth knowledge of the transaction enables us to be most efficient in resolving tax disputes.

The BEPS project and related tax changes are ‘the end of an era’ in tax planning, though this is not the end of tax planning as such. In our view, it is not the first change of this scale. The introduction of CFC rules in developed countries seemed to bring an end to international planning several decades ago.

In fact, it only prompted the development of hybrid instruments. Nevertheless, the magnitude and global reach of BEPS are greater than ever before. The paramount issue today is that tax payers should not expect any grandfathering or stabilisation. AVELLUM see on a global scale that governments are trying to impose taxes retroactively. The argument they raise is that taxation in the past was formally compliant, but unfair and abusive or even immoral. We believe that this fundamentally undermines legal certainty for the taxpayers in an unprecedented way.

One of the reasons for volatility and complexity in tax rules is the global change of G20 tax vector. For many years, the OECD stated the developed international system to protect their residents from taxation abroad (in source states). The digital economy and globalisation made these states vulnerable to all the leakages of the system they developed. It was expected that in such situation, developed countries would introduce effective protective measures.

Traditionally, Ukrainian tax authorities are quite aggressive during tax audits and usually issue significant tax assessments. Many of these are not well-justified. As a result, Ukrainian businesses pose an inherent risk of tax assessment and tax controversy.

At the international stage MNEs are not used to such an aggressive approach in tax affairs. Apart from certain ‘traditional’ tax risk zones (such as transfer pricing in pharmaceutical industry and dealings with several emerging markets known for protection of tax base), MNEs were not subject to imminent and constant risk of tax controversy.

Tax planning projects in our firm face similar challenges as the industry in general. The global reshaping of the tax landscapes leads to significant changes in tax planning strategy and tactics. Instead of creative experimentation with forms and substance, planning is concerned with the matching and mapping of the genuine business structures, along with the available tax incentives.

In the same time, our tax controversy practice does not seem to have any significant challenges. One of the biggest changes we expect in this sphere is increasing role of alternative dispute resolution methods in tax matters.

Company: AVELLUM
Name: Vadim Medvedev
Email: vmedvedev@avellum.com
Web: www.avellum.com
Address: 38 Volodymyrska
Str., 4th floor, 01030, Kyiv,
Ukraine
Phone: 38(044)591 33 55

 

 

 

 

Categories: Legal


You Might Also Like
Read Full PostRead - Eye Icon
VTech to Acquire LeapFrog Enterprises
M&A
05/02/2016VTech to Acquire LeapFrog Enterprises

VTech Holdings Limited, aleader in electronic learning products and cordless telephones,and LeapFrog Enterprises, Inc, a developer of educational entertainment for children, announces today that the two companies have entered into a merger agreement whereby VT

Read Full PostRead - Eye Icon
Changing the Game
Innovation
23/03/2021Changing the Game

Outdoor equipment must stand up to the most rigorous of conditions, not only competing with the stresses that nature provides, but the strain of continual use by fitness fanatics and children. Recognised as the Most Outstanding Outdoor Fitness Gym & Playgr

Read Full PostRead - Eye Icon
Gen Z Is Coming: How Luxury Brands Can Survive and Thrive With the Next Generation 
News
20/07/2022Gen Z Is Coming: How Luxury Brands Can Survive and Thrive With the Next Generation 

Younger generations are continuing to encroach on the luxury market, and for brands it is important they get their share. Set to make up 50% of the whole market by 2025, Gen Zs and Millennials are fast becoming key stakeholders in the industry. For luxury bran

Read Full PostRead - Eye Icon
Striving to Deliver Excellence
News
31/07/2019Striving to Deliver Excellence

ACCRALAW is a cohesive, multidisciplinary team of legal professionals who possess in-depth knowledge of wide-ranging legal practices and specialized fields.

Read Full PostRead - Eye Icon
Best for Employment Visa Advice – Colorado
Legal
17/05/2016Best for Employment Visa Advice – Colorado

Maria Lourdes Rodriguez, Esq. started Rodriguez Law Firm in 2005 after she realised the lack of trustworthy immigration lawyer advice in the Colorado region.

Read Full PostRead - Eye Icon
10 Cryptocurrencies with The Biggest Growth Potential to Buy Right Now
News
06/10/202210 Cryptocurrencies with The Biggest Growth Potential to Buy Right Now

When you're just starting in the world of cryptocurrency, the dozens of different cryptocurrencies, from Bitcoin and Ethereum to Dogecoin and Tether, might be intimidating. To help you gain your bearings, these are the top ten cryptocurrencies with the biggest

Read Full PostRead - Eye Icon
Evotec Announces Its Intent to Acquire Cyprotex Plc
Innovation
26/10/2016Evotec Announces Its Intent to Acquire Cyprotex Plc

Acquisition would add world-leading high-quality ADME-Tox services and strengthen Evotec's leadership in drug discovery

Read Full PostRead - Eye Icon
6 Ways RPA Can Transform Your Small Business
News
30/11/20226 Ways RPA Can Transform Your Small Business

Robotic process automation (RPA) is a hot topic among businesses for many reasons. It increases productivity, which in turn increases profit. Business efficiency is another area where RPA can do wonders. While RPA can impact a company positively, many business

Read Full PostRead - Eye Icon
How to Manage Your Budget During Inflationary Times
Finance
20/04/2022How to Manage Your Budget During Inflationary Times

At this point, there is no getting away from the word inflation. Everyone is talking about it, many complaining about it, but do you know how to take action to survive it? Depending on your age range, you may or may not have experienced life in inflationary ti



Our Trusted Brands

Acquisition International is a flagship brand of AI Global Media. AI Global Media is a B2B enterprise and are committed to creating engaging content allowing businesses to market their services to a larger global audience. We have a number of unique brands, each of which serves a specific industry or region. Each brand covers the latest news in its sector and publishes a digital magazine and newsletter which is read by a global audience.

Arrow