© 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
CC McLays Completes Acquisition of TPSG Procurement
M&A
18/06/2024CC McLays Completes Acquisition of TPSG Procurement

CCS McLays has successfully acquired TPSG Procurement as it looks to strengthen its presence in the food and retail packaging sectors as part of its growth strategy.

Read Full PostRead - Eye Icon
Tesco to Sell South Korean Subsidiary Following Expansion into Virtual Market
Finance
25/06/2015Tesco to Sell South Korean Subsidiary Following Expansion into Virtual Market

Early reports indicate Orion Confectionery, MBK Partners and The Carlyle Group all vying to buy into Tesco’s South Korean venture Homeplus.

Read Full PostRead - Eye Icon
Yantai Xinchao to Acquire Texas Oil Fields for $1.3 Billion
Finance
27/10/2015Yantai Xinchao to Acquire Texas Oil Fields for $1.3 Billion

With China's increased interest and investment in the energy, Yantai Xinchao plan to purchase giant oil fields in Texas.

Read Full PostRead - Eye Icon
Using Technology to Protect Your Finances in 2023
Finance
01/12/2022Using Technology to Protect Your Finances in 2023

Businesses and individuals across the globe are facing difficulties due to rising inflammation levels in the current geopolitical situation. People are already beginning to make adjustments to combat these difficulties. Here, we will discuss how using technol

Read Full PostRead - Eye Icon
Essential eCommerce Features for Major Growth
Strategy
06/11/2020Essential eCommerce Features for Major Growth

With the right strategies, you can give your eCommerce business the best chance of success regardless of the circumstances. A mixture of customer loyalty, building a modern eCommerce website and focusing on long-term marketing efforts has proven to work for ot

Read Full PostRead - Eye Icon
The ABCs of Cybersecurity: How Small Businesses Can Safeguard Their Online Safety
News
25/01/2022The ABCs of Cybersecurity: How Small Businesses Can Safeguard Their Online Safety

Any business can be a target of hackers. Company size doesn't matter—as long as you have what cybercriminals want—you are their prey.

Read Full PostRead - Eye Icon
Most Innovative Law Firm of 2016 – Italy
Legal
04/05/2016Most Innovative Law Firm of 2016 – Italy

As a lawyer and professional representative before the Italian, community and European authorities, Domenico de Simone has devoted himself exclusively to intellectual property since 1972.

Read Full PostRead - Eye Icon
Procurement Fraud: The Corporate Landscape’s Nemesis
Strategy
29/04/2019Procurement Fraud: The Corporate Landscape’s Nemesis

As bakery chain Patisserie Valerie plunges into administration following allegations of fraud from third party contractors, we explore the issues around procurement fraud and how it can be prevented.  Fraud within any area of a business is a devastating occur

Read Full PostRead - Eye Icon
JLL Advise Ankkurikadun Kiinteistöt’s Purchase of Properties in Finland and Sweden
M&A
08/07/2015JLL Advise Ankkurikadun Kiinteistöt’s Purchase of Properties in Finland and Sweden

JLL Advise Ankkurikadun Kiinteistöt's Purchase of Properties in Finland and Sweden



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