© 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
6 Sustainable Promotional Products That Leave a Memorable Brand Impression
News
06/11/20236 Sustainable Promotional Products That Leave a Memorable Brand Impression

IMG Source – https://unsplash.com/photos/a-close-up-of-a-paper-bag-on-a-table-NzO8KVLzpQc In an era where environmental concern informs consumer behavior more than ever before, businesses are under increasing pressure to align with these values. Traditio

Read Full PostRead - Eye Icon
The Beginning of the End for Bad Biofuels
Innovation
15/04/2015The Beginning of the End for Bad Biofuels

Today the Environment Committee of the European Parliament has confirmed, with an overall majority, a political deal with Council to cap the use of first generation biofuels.

Read Full PostRead - Eye Icon
How to Secure Consistent Work in a Competitive Freight Market
News
13/09/2024How to Secure Consistent Work in a Competitive Freight Market

The logistics and freight industry has seen significant changes over the past few years. The global market is now forecast to be worth $18.69 billion by 2026, at a CAGR of 4.4%. As global trade expands, new technologies emerge, and client needs evolve, securin

Read Full PostRead - Eye Icon
Creating a Tailored Acquisition & Integration Strategy
M&A
26/03/2018Creating a Tailored Acquisition & Integration Strategy

MVF, a global customer generation firm based in London, has made several acquisitions over the past twelve months - including Startups.co.uk, the UK’s number one website for entrepreneurs, startups and small business and Tech.co, a US based tech news and res

Read Full PostRead - Eye Icon
Striving for Perfection
Leadership
13/02/2017Striving for Perfection

SARC is a firm with 17 senior partners and a pan India presence with foot prints in London and Toronto. To win the 2017 Ones to Watch in Consultancy award is of course a great honour, one feels great and on top of the world.

Read Full PostRead - Eye Icon
How Corporate Social Responsibility Can Prevent Workplace Accidents: A Legal Perspective
News
30/08/2024How Corporate Social Responsibility Can Prevent Workplace Accidents: A Legal Perspective

Corporate social responsibility (CSR) is fundamental to a company’s long-term relationship with its employees, the communities it operates in, and the protection of the environment. The role of CSR in preventing workplace accidents is increasingly being

Read Full PostRead - Eye Icon
Plesner Advise Solina in Acquisition of Paulig Flavours Division
Legal
07/05/2015Plesner Advise Solina in Acquisition of Paulig Flavours Division

Solina Group (“Solina”) has signed a binding agreement to acquire from Paulig its INDUSTRIAL FLAVOURING DIVISION. Paulig Group (“Paulig”) is the selling majority shareholder. The IFD management will join Solina Group.

Read Full PostRead - Eye Icon
Ones to Watch for 2016: The Best Boutique Accounting Firm
Legal
06/06/2016Ones to Watch for 2016: The Best Boutique Accounting Firm

Vision Consulting is a boutique firm of chartered accountants and registered auditors set up to service the business needs of their clients.

Read Full PostRead - Eye Icon
Dominica Citizenship by Investment: A Path to Caribbean Paradise by Global Residence Index
News
29/12/2023Dominica Citizenship by Investment: A Path to Caribbean Paradise by Global Residence Index

Who does not want to get their dream home in the dreamy landscapes of Dominica, in the paradise of Caribbeans? The island nation of the Caribbean, Dominica, is one of the most unexplored lands. Moreover, the natural hot springs, coastal views, and lively rainf



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