© 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
Enhancing Sustainability and Efficiency with Commercial Heating Systems
News
19/12/2023Enhancing Sustainability and Efficiency with Commercial Heating Systems

When it comes to heating systems on commercial premises, gas boilers remain the go-to option for businesses of all sizes and industries. These appliances offer the perfect balance of power, performance, reliability, and efficiency, while also allowing for besp

Read Full PostRead - Eye Icon
Committed to Care
Legal
23/07/2019Committed to Care

Templars Law is a full service law firm with extensive knowledge regarding how to handle the legal needs of clients in Nigeria’s peculiar business environment.

Read Full PostRead - Eye Icon
How to Repay Your Loan Faster?
Finance
23/02/2022How to Repay Your Loan Faster?

Whenever you’re in debt, your main goal should be to repay it as fast as possible. Sure, taking out a loan can be a good thing as it provides access to needed credit.

Read Full PostRead - Eye Icon
Innovating Financial Services with Banking APIs
Finance
06/06/2016Innovating Financial Services with Banking APIs

Traditionally, financial services and banking have been among the most conservative industries.

Read Full PostRead - Eye Icon
Transparency, Integrity, Communication, Kindness
Corporate Social Responsibility
08/08/2022Transparency, Integrity, Communication, Kindness

Founded in 1996, Edkey Inc is a non-profit organisation which manages 28 schools and programmes across Arizona including 17 Sequoia Charter Schools. It works together with families to provide high quality educational services for their K-12 children by creatin

Read Full PostRead - Eye Icon
Welltower Completes Acquisition of Premier Seniors Housing Portfolio
Finance
14/10/2016Welltower Completes Acquisition of Premier Seniors Housing Portfolio

Welltower Inc. (NYSE: HCN) today announced it has completed the previously announced acquisition of the Vintage Senior Living portfolio for a purchase price of $1.15 billion.

Read Full PostRead - Eye Icon
Top Marks
Leadership
03/10/2017Top Marks

Top Marks

Read Full PostRead - Eye Icon
How To Process ABA Claims: A Step-By-Step Guide
News
23/10/2023How To Process ABA Claims: A Step-By-Step Guide

Ensure ABA claims are processed timeously with our guide. Understanding how to process ABA claims for healthcare professionals, medical staff, and private individuals is essential in the operating field of behavioural health. Because Applied Behaviour Analysis

Read Full PostRead - Eye Icon
Sie Holding acquires 51% of shares in Tagor Electronic doo Nis.
Legal
05/05/2015Sie Holding acquires 51% of shares in Tagor Electronic doo Nis.

Marija Tasic and Vanja Stojanovic, attorneys at law from Tasic & Partners, after months of negotiation, have finalized the acquisition between Austrian company System Industrie Electronic Holding AG (SIE Holding) and Tagor Electronic doo Nis, leading manufactu



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