© 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
Is Your Recruitment Business Ready to Scale
News
23/12/2024Is Your Recruitment Business Ready to Scale

Scaling your recruitment business can be one of the most challenging but exciting times in your company’s journey. After working to establish yourself and a sustainable way of working, it’s time to take your approach and apply it to a larger busine

Read Full PostRead - Eye Icon
Best Caribbean Restaurant – USA
Finance
01/07/2016Best Caribbean Restaurant – USA

Jamaican Grill is a chain of restaurants specialising in offering flavourful, Jamaican cuisine and excellence client service. Here at Jamaican Grill Restaurants is a totally unique BBQ concept that fuses the flavours of Jamaica, Guam and the Philippines.

Read Full PostRead - Eye Icon
E2V Technologies surges almost 50% after being acquired by Teledyne
Innovation
31/01/2017E2V Technologies surges almost 50% after being acquired by Teledyne

E2V Technologies, a British technology firm that specializes in the development of radio amplifiers, microprocessors and imaging sensors for the medical technology, aerospace, and military sectors, was acquired by USA-based Teledyne in a takeover deal last wee

Read Full PostRead - Eye Icon
Beyond the Crash: Strategic Risk Management and the True Cost of Traffic Accidents for Businesses
Legal
27/01/2026Beyond the Crash: Strategic Risk Management and the True Cost of Traffic Accidents for Businesses

In today’s interconnected economy, the impact of serious road traffic accidents extends far beyond immediate medical bills and vehicle damage. For organisations that underwrite risk, manage fleets, or provide services tied to employee safety and liability, u

Read Full PostRead - Eye Icon
Troika Media Group and Mission Join Forces
Finance
03/08/2018Troika Media Group and Mission Join Forces

Troika Media Group and Mission Join Forces to Form Troika/Mission Group - TMG

Read Full PostRead - Eye Icon
Government Contracts 101 for Businesses: Tips, Processes, and Best Companies for Contract Consulting
Corporate Social Responsibility
21/08/2025Government Contracts 101 for Businesses: Tips, Processes, and Best Companies for Contract Consulting

Government contracts create monetary opportunities for businesses across various industries and sizes, delivering billions of dollars in federal, state and local spending annually. Winning them often provides steady revenue, improved credibility and long-term

Read Full PostRead - Eye Icon
Resolving Disputes Through Arbitration
Strategy
16/05/2016Resolving Disputes Through Arbitration

More than ever before, companies across the financial landscape are realising the benefits of alternative dispute resolution.

Read Full PostRead - Eye Icon
Driving Tomorrow: LeddarTech’s Revolutionary Path in Automotive Software Technology
Innovation
19/12/2023Driving Tomorrow: LeddarTech’s Revolutionary Path in Automotive Software Technology

Founded in 2007, LeddarTech Inc is a global software company based in Québec City, that also has a strong presence in Montreal, Toronto, and Tel Aviv, Israel, thanks to its additional R&D centres in these locations.

Read Full PostRead - Eye Icon
Bringing Content to Life Across Major Media Channels
Leadership
24/11/2025Bringing Content to Life Across Major Media Channels

Lightcast.com’s OTT Media Cloud launches and monetises TV, mobile, web & social apps—end-to-end streaming, real-time control and faster multi-platform growth.



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