© 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
Wage Disputes 101: Your Rights as an Employee and How to Fight for Fair Pay
Legal
26/03/2026Wage Disputes 101: Your Rights as an Employee and How to Fight for Fair Pay

It may be vital to be properly compensated for your labor, but it is also your right. Yet, wage conflicts occur more regularly than most workers think, whether through unpaid overtime or unpaid wages. If something seems wrong, it is a good idea to investigate

Read Full PostRead - Eye Icon
CEO of the Year – Maryland
Leadership
02/02/2016CEO of the Year – Maryland

Schul International offers a range of premium quality joint sealants with a specialization in construction sealants/chemicals, metal fabrication, high tech automation and robotics.

Read Full PostRead - Eye Icon
The rise of petrol prices and the global impact it has
Finance
23/04/2019The rise of petrol prices and the global impact it has

The average price of a litre of petrol at the end of 2018 was £1.21 in the UK, whereas a decade ago the figure was closer to £0.89 per litre. Price surges are reflective of steep inflation at various historical points, but what does 2019 hold for our empty t

Read Full PostRead - Eye Icon
Switching From Corporation To LLC: 4 Things To Know
Corporate Social Responsibility
25/04/2023Switching From Corporation To LLC: 4 Things To Know

Business goals, partnerships, and management styles can change occasionally. When the directors and executives of an established corporation wish to enjoy a more flexible management style and profit allocation, switching to a limited liability company (LLC) st

Read Full PostRead - Eye Icon
Leading Insolvency and Asset Recovery Expert
Leadership
11/06/2019Leading Insolvency and Asset Recovery Expert

Grant Thornton BVI Ltd specialises in providing recovery and restructuring services for or to companies registered in the BVI and the Eastern Caribbean. Following their success in Acquisition Intl.’s Leading Advisor 2018 where they were awarded the accolade

Read Full PostRead - Eye Icon
Pamplona Capital Management Acquires Controlling Interest in Latham Pool Products
Finance
03/01/2019Pamplona Capital Management Acquires Controlling Interest in Latham Pool Products

Pamplona Capital Management (“Pamplona”), is pleased to announce that it has acquired a controlling interest in Latham Pool Products, Inc. (“Latham” or “the Company”) from Wynnchurch Capital (“Wynnchurch”), which will remain a significant inves

Read Full PostRead - Eye Icon
CMS Advise During Echo BV’s Acquisition of a Stake in Echo Investment
Legal
20/08/2015CMS Advise During Echo BV’s Acquisition of a Stake in Echo Investment

CMS Advise During Echo BV’s Acquisition of a Stake in Echo Investment

Read Full PostRead - Eye Icon
Investors Urged to Invest Overseas to Mitigate Risks Posed by UKIP Gains
Finance
23/02/2015Investors Urged to Invest Overseas to Mitigate Risks Posed by UKIP Gains

Investors need to take precautions against a fall in the value of UK assets, which may be triggered by UKIP gains at the polls.

Read Full PostRead - Eye Icon
Taylor Wessing Advises THMMS’s Acquisition of EliteMedianet
Legal
13/08/2015Taylor Wessing Advises THMMS’s Acquisition of EliteMedianet

Taylor Wessing Advises THMMS's Acquisition of EliteMedianet



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