© 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
Romania: Flying High
Finance
06/10/2015Romania: Flying High

For almost 25 years, Deloitte Romania has been offering customers high quality services thanks to its extensive knowledge, innovation, experience and wide range of services.

Read Full PostRead - Eye Icon
Bigadvantage: Leadership and Innovation in Management Consultancy and Training
News
24/03/2025Bigadvantage: Leadership and Innovation in Management Consultancy and Training

Bigadvantage is currently an essential reference in the management consultancy and training sector in Portugal.

Read Full PostRead - Eye Icon
AI and Machine Learning Skills in Highest Demand from Employers in 2024
News
26/02/2024AI and Machine Learning Skills in Highest Demand from Employers in 2024

Nearly a third of employees have little understanding of how to use AI and data and less than one in ten have received training on AI tools in the past 12 months

Read Full PostRead - Eye Icon
A Warming Trend:  US Consumers Step into the Sunshine
Finance
12/02/2015A Warming Trend: US Consumers Step into the Sunshine

Mesirow Financial’s Chief Economist says a profound shift has occurred in American consumer confidence.

Read Full PostRead - Eye Icon
Leaders in Law
Innovation
11/04/2019Leaders in Law

Since their inception in 1993, Vietnam International Law Firm (VILAF – Hong Duc) (“VILAF”) has developed into an independent law firm. Recently, we profiled VILAF and caught up with Ngoc Anh who provided us with a glimpse into the innerworkings of the su

Read Full PostRead - Eye Icon
Transcosmos Acquires 100% Ownership of Social Gear, a Social Media Operational Support Company
M&A
20/05/2016Transcosmos Acquires 100% Ownership of Social Gear, a Social Media Operational Support Company

transcosmos inc. has made additional investment in SOCIAL GEAR PTE LTD (Headquarters: Singapore; CEO: Shunsuke Sato; hereafter, Social Gear), a company which provides social media operational support, and acquired 100% ownership of the company.

Read Full PostRead - Eye Icon
UK Law Firms: More Cyber Security Support is Urgently Needed from MSPs
Legal
19/10/2023UK Law Firms: More Cyber Security Support is Urgently Needed from MSPs

Recent research by the National Cyber Security Centre (NCSC) has found UK law firms are increasingly appealing targets for cybercriminals interested in stealing and exploiting client data.

Read Full PostRead - Eye Icon
Not Losing Interest
Finance
13/02/2017Not Losing Interest

Cavmont Bank Ltd’s vision is to be a world class bank rated amongst the best in Zambia with a focus on partnering with all their stakeholders. Following their success in winning the 2016 Banker of the Year Zambia

Read Full PostRead - Eye Icon
Banking on Success
Finance
26/01/2017Banking on Success

Founded in 1899, and headquartered in Nicosia, Cyprus, Bank of Cyprus is today the leading banking and financial services group in Cyprus, with significant market shares across all businesses. Today, Marios Skandalis is the Director of the Group Compliance Div



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