© 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
Apple Watch App Technology Spreads its Net Wider
Innovation
26/10/2015Apple Watch App Technology Spreads its Net Wider

Montgomery County Employees Federal Credit Union Introduces Apple Watch App Technology

Read Full PostRead - Eye Icon
Property Acquisition CEO Secures Success
Leadership
08/10/2019Property Acquisition CEO Secures Success

London’s premier property Search, Investment, Development and Acquisition firm, Rehoboth has consistently delivered for the UK’s most prestigious property owners and developers. Rehoboth engages in development projects with industry partners to help allevi

Read Full PostRead - Eye Icon
5 Ways to Optimize AWS Migration Costs
Innovation
27/07/20235 Ways to Optimize AWS Migration Costs

Increasingly more enterprises switch to AWS by performing the migration themselves or outsourcing AWS migration services. According to Amazon, 51% of AWS adopters report reduced operational costs, 62% IT staff productivity increase, and 94% downtime reduction.

Read Full PostRead - Eye Icon
Moving Class Outside: Adjusting Academics
News
13/08/2021Moving Class Outside: Adjusting Academics

When you think of the typical classroom, you’re probably picturing brick walls, rows of desks, a chalkboard and a few decorations that match the subject being taught. Over this past year, though, the traditional classroom has been flipped. The pandemic sent

Read Full PostRead - Eye Icon
Innovators In Technology
Innovation
07/05/2021Innovators In Technology

Procon Analytics is a leading innovator of automotive IoT and big data insights, focused on capturing and translating data into actionable business intelligence. Learn more from company leaders about the future of their technology.

Read Full PostRead - Eye Icon
Banking on DevOps
Finance
08/05/2018Banking on DevOps

Andy Cureton, Founder and Managing Director, ECS Digital, looks at how, in a competitive environment, banks and other organisations can use the latest IT and business methodologies to modernise their IT systems to meet customer expectations and comply with reg

Read Full PostRead - Eye Icon
When an Employee Is Accused of a DUI: What Delivery and Logistics Companies Need to Consider
Legal
29/01/2026When an Employee Is Accused of a DUI: What Delivery and Logistics Companies Need to Consider

For delivery and logistics companies, employees who operate vehicles represent far more than operational capacity. They are closely tied to brand reputation, safety standards, and contractual obligations. When an employee is accused of driving under the influe

Read Full PostRead - Eye Icon
7 Facts That Prove Entrepreneurship Is Thriving in UK Post Brexit – Survey
Innovation
17/11/20167 Facts That Prove Entrepreneurship Is Thriving in UK Post Brexit – Survey

Entrepreneurial spirit and optimism remains high in the UK according to new UK research released by Amway.

Read Full PostRead - Eye Icon
Strong Management More Important Than Ever in UK
Innovation
29/10/2019Strong Management More Important Than Ever in UK

We are experiencing a resurgence in the popularity of tough bosses in the UK. The “Imperial CEO” started to become less fashionable in the eighties with the decline in deference. The nineties saw the reputation of strong business leadership tarnished with



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