Our purpose

As governments introduce increasingly complex tax laws to address global transparency, digital transformation, and cross-border business models, navigating special tax regulations has become a critical challenge—and a powerful opportunity. We support clients in regulated sectors and multinational environments by advising on jurisdiction-specific provisions, incentive regimes, anti-avoidance rules, and international tax alignment. Whether you operate in a free zone, manage a regional holding structure, or face enhanced reporting obligations, our team brings clarity and strategic foresight. Headquartered in Armenia. Operating worldwide. Trusted across industries.

What are special tax regulations?

Special tax regulations are non-standard provisions designed for specific industries, structures, or circumstances. They include:

Preferential regimes: Free Economic Zones, IT sector incentives, R&D tax credits
Anti-avoidance frameworks: GAAR, SAAR, CFC rules, hybrid mismatch regulations
Disclosure and reporting obligations: DAC6, CbCR, FATCA, CRS, Pillar 2 notifications
Sector-specific tax treatment: financial services, energy, digital platforms, NGOs
Cross-border structuring rules: treaty tie-breakers, substance tests, exit taxes

Regulatory mapping and eligibility review

Qualification for FEZ, IT, innovation box, or R&D incentives

Application of OECD Pillar 2 rules (Global Minimum Tax)

Analysis of EU ATAD and Armenia-specific anti-avoidance measures

Substantive presence and beneficial ownership tests

Strategic tax structuring under regulation

International holding and IP company structuring

Treaty-based optimization with economic substance

Sector-specific structuring: finance, real estate, tech, manufacturing

Exit tax planning and hybrid entity evaluation

Disclosures, rulings and compliance alignment

DAC6, FATCA, CRS, and CbCR reporting frameworks

APA, ruling requests, and regulatory pre-clearance

Step plan preparation and legal merger support

Audit-proof documentation aligned with OECD and national standards

Industry-specific tax regulation advisory

Banking & Finance: thin cap, withholding tax, base erosion rules

Digital Economy: digital service taxes, platform VAT, IP location

Energy: resource rent taxes, ring-fencing, carbon taxation

NGOs & Donor-Funded Projects: VAT exemptions, indirect tax planning

Why it matters

We protect your compliance and position your structure for long-term efficiency. Failure to navigate special tax rules may result in:

Loss of treaty relief or preferential tax status
Exposure to significant audit risk and reputational damage
Denial of exemptions or deductions
Misalignment with local GAAR/SAAR rules

Who we advise

We support organizations that demand more than basic compliance. Our clients include:

Multinational groups expanding across borders
Regulated financial institutions and fintech firms
IP-heavy startups in tech, SaaS, and biotech
Energy and infrastructure operators
NGOs, donor-funded entities, and multilateral organizations
International investors and private equity firms

Optional enhancements for clients

Sector-specific legal briefs (finance, energy, real estate, digital economy)
Whitepapers: “Pillar 2 and Preferential Regimes in Practice”
Interactive Compliance Maps (DAC6, Pillar 2, ATAD coverage)

Why partner with us

Policy-driven execution

Strategic decisions aligned with OECD, EU, and national laws

Multijurisdictional expertise

Seamless advisory across continents, sectors, and tax systems

Audit-ready documentation

Defensible filings and disclosures, even under scrutiny

Regional insight

Based in Armenia, equipped for Eurasian, EU, and MENA markets

FAQ

Frequently asked questions

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

Can you manage tax digitally across multiple jurisdictions?

Yes. We use dashboards, automation tools, and data connectors to monitor global tax positions.

Do you support audit or court defense?

Yes. We provide pre-litigation risk assessment, prepare documentation, and represent clients in disputes.

What is responsible tax planning?

Tax strategies that are legally sound, aligned with ESG, and reputationally resilient.

Do you align with global regulatory frameworks?

We follow OECD BEPS, EU DAC6, CRS, and local GAAR principles across jurisdictions.

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Redefine your tax function