© 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
Business Merger vs Consolidation: What’s The Difference?
M&A
24/09/2021Business Merger vs Consolidation: What’s The Difference?

With the continuously evolving economy, business mergers and consolidations are becoming more common. Often, there are also legalities involved in both processes, which makes it important to consult with law experts.

Read Full PostRead - Eye Icon
Restructuring options for financially-distressed employers
Finance
17/03/2021Restructuring options for financially-distressed employers

Whilst support has been made available by the Government to assist employers, the pandemic has still seen huge numbers of job losses. The pain has been felt in all sectors. So, what restructuring options are available for directors to consider in the hope of r

Read Full PostRead - Eye Icon
How To Buy Small Businesses With Little-To-No Money Down In 2024
News
18/01/2024How To Buy Small Businesses With Little-To-No Money Down In 2024

Source: Unsplash In 2024, the allure of buying small businesses is heightened by a few more factors. First, the pandemic aftermath has led to numerous market gaps waiting to be filled – a prime opportunity for nimble small businesses. Also, the rise of d

Read Full PostRead - Eye Icon
How to Choose the Right Vessel for Your Business Needs
News
23/11/2023How to Choose the Right Vessel for Your Business Needs

Businesses exporting heavy-duty products or goods will have to consider the right type of cargo transportation. If goods are exported internationally, this will require consideration of the right type of vessel or ship.

Read Full PostRead - Eye Icon
Meet the CEOs
Leadership
22/02/2016Meet the CEOs

Meet the CEOs

Read Full PostRead - Eye Icon
The Findis Group Acquires Desamais Distribution
M&A
31/07/2015The Findis Group Acquires Desamais Distribution

The Findis Group Acquires Desamais Distribution

Read Full PostRead - Eye Icon
Epic Health Services Completes Acquisition of Loving Care Agency
Finance
08/04/2015Epic Health Services Completes Acquisition of Loving Care Agency

Epic Health Services Completes Acquisition of Loving Care Agency

Read Full PostRead - Eye Icon
Unipart Launches National Productivity Campaign in UK
Finance
12/11/2015Unipart Launches National Productivity Campaign in UK

According to the company, which has its headquarters in Oxford, productivity is Britain's biggest issue when it comes to economic growth.

Read Full PostRead - Eye Icon
Why Your Chatbots Are Making Debtors More Angry
Finance
27/04/2023Why Your Chatbots Are Making Debtors More Angry

The use of automated communication tools, such as chatbots, to speak to customers has grown since the pandemic. One in four customer service companies are using AI, with 31% planning to introduce these tools in the next 18 months. The global chatbot market is



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