Our purpose

Our pre-dispute advisory ensures compliance and resilience for Armenia’s regulatory environment in 2025. Tailored for MNEs, we align with transfer pricing frameworks. We mitigate tax risks through proactive governance, ensuring audit resilience and compliance. Our services strengthen positions and support MNE transfer pricing strategies for confidence.

Risk diagnostics

Assesses tax positions to identify audit triggers

Maps risks using OECD, BEPS benchmarks

Analyzes transactions for regulatory alignment

Supports MNEs in minimizing tax disputes

Preventive structuring

Restructures transactions to meet tax laws

Enhances documentation for regulatory compliance

Evaluates agreements for tax scrutiny

Aligns MNE strategies with compliance needs

Pre-audit simulation

Simulates audits to test tax robustness

Assesses documentation for inquiry readiness

Prepares responses to audit challenges

Enhances MNE audit preparedness

Tax control framework

Designs TCFs for compliance-by-design

Integrates monitoring for tax risks

Aligns with IFRS, EAEU standards

Supports MNE scalable compliance systems

Who we advise

We serve clients for whom tax resilience is a trust function:

Multinational groups: Managing complex structures.
Investment funds: Ensuring compliance readiness.
Regulated industries: Navigating high scrutiny.
Companies pre-IPO/M&A: Preparing due diligence.
Holding structures: Mitigating tax exposures.
C-suite executives: Driving tax strategy.

Real-world impact: what our clients achieve

The challenge

High tax dispute risks

Weak audit defensibility

Complex compliance demands

Inconsistent documentation

Our strategic response

Tailored risk diagnostics

Robust structuring, TCFs

Pre-audit simulations

Transfer pricing-aligned solutions

Achieved results

Reduced dispute probability

Enhanced audit readiness

Full compliance, transparency

Aligned transfer pricing outcomes

Delivery models

Risk assessment: Diagnostics, red-flag mapping

Structuring: Transaction, documentation plans

Audit prep: Simulations, response strategies

Governance: TCFs, compliance monitoring

Why partner with us

Tax risk expertise

Deep OECD, BEPS knowledge.

Compliance assurance

Aligns with Armenian laws.

Proven methods

TCFs, audit simulations.

Resilience impact

Builds defensible positions.

Tailored solutions

Fits MNEs, funds.

FAQ

Frequently asked questions

Explore our frequently asked questions to learn more about TML’s features, security, integration capabilities, and more

What is pre-dispute advisory?

It mitigates tax risks proactively, ensuring compliance and audit resilience through governance.

What does risk diagnostics involve?

We assess tax positions, map red flags, and align with OECD, BEPS standards.

How do you strengthen tax positions?

We restructure transactions, enhance documentation, and evaluate substance for defensibility.

Can you support MNE tax strategies?

Yes, we align governance with transfer pricing for global compliance and resilience.

What is a tax control framework?

TCFs embed compliance-by-design, integrating continuous monitoring for tax risk management.

How do pre-audit simulations help?

We simulate audits to assess readiness, preparing robust responses to minimize risks.

What deliverables do you provide?

We deliver risk diagnostics, TCFs, audit simulations, and compliance documentation.

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Pre-dispute advisory and prevention