© 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
Towers Watson Acquires  Saville Consulting
M&A
08/05/2015Towers Watson Acquires Saville Consulting

Acquisition expands Towers Watson’s leadership and talent management offering and strengthens its position as a leading Human Resources (HR) software provider.

Read Full PostRead - Eye Icon
The Role of Construction Accident Statistics in Business Planning and Risk Management
News
16/10/2024The Role of Construction Accident Statistics in Business Planning and Risk Management

Construction accident statistics are the central component of risk management in the construction industry. By analyzing and understanding accident data, companies can identify potential hazards, implement safety measures, create a safer environment for their

Read Full PostRead - Eye Icon
Within The Financial Space, What Is A Security?
Finance
14/01/2019Within The Financial Space, What Is A Security?

Whilst many have heard the term security before, equally many do not understand its implications as a noun. Within the financial space, a security is, put simply, a certificate or form of declaration which indicates that something is tradable, and therefore ha

Read Full PostRead - Eye Icon
Proudly at the Forefront of International Business Law
Legal
08/10/2024Proudly at the Forefront of International Business Law

Among the specialised law firms in Europe, some stand out as eminent options for meeting clients' business law needs.

Read Full PostRead - Eye Icon
Avoid These 6 Intellectual Property ‘Business Killers’
Legal
27/01/2023Avoid These 6 Intellectual Property ‘Business Killers’

According to JiNan, understanding patent trends can drastically protect existing intellectual property and increase valuation as businesses develop that which is new. However, she cautions that there are a few specific “business killing” myths and mistakes

Read Full PostRead - Eye Icon
Strong Increase of Equity Trading Volumes ( 17.4%) in 2014
Finance
04/03/2015Strong Increase of Equity Trading Volumes ( 17.4%) in 2014

The World Federation of Exchanges Ltd. released its Annual Statistics Market Highlights report.

Read Full PostRead - Eye Icon
5 Roles of Tax Accountants in Gold Coast in Financial Planning and Wealth Management
News
08/07/20245 Roles of Tax Accountants in Gold Coast in Financial Planning and Wealth Management

5 Roles of Tax Accountants in Gold Coast in Financial Planning and Wealth Management Tax accountants in Gold Coast play a pivotal role in financial planning and wealth management. Their expertise extends beyond mere tax preparation, encompassing strategic plan

Read Full PostRead - Eye Icon
Are Students Being Bullied out of the Rental Market?
Strategy
13/08/2015Are Students Being Bullied out of the Rental Market?

Buying a property in the UK is becoming increasingly unaffordable, driving-up demand and prices for those wanting to rent. Research suggests that by 2025 over 50% of 20-39 years olds will be privately renting.

Read Full PostRead - Eye Icon
Autonomous Technology Can Mitigate the Business Impact of the Coronavirus
Innovation
12/03/2020Autonomous Technology Can Mitigate the Business Impact of the Coronavirus

The coronavirus has exposed the soft underbelly of critical infrastructure and industrial sites worldwide – workforce availability. As more and more companies implement business continuity plans to deal with the outbreak, fewer and fewer employees are able t



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