Published in last 50 years
Articles published on Tax Code
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- Research Article
- 10.24144/2307-3322.2025.90.3.33
- Oct 26, 2025
- Uzhhorod National University Herald. Series: Law
- P V Kolomiiets
In this article, the author emphasizes some key problems of ensuring tax security in Ukraine. The influence of tax benefits, which, when used as a support tool, simultaneously formed the risks of budget losses and violation of the principle of equality of taxpayers, deserves attention. The author’s definitions of the categories of tax security and its legal regulation are formulated. It is emphasized that the issues of legal regulation of relations in the field of collecting taxes and fees should be considered through the prism of human centrism, since both taxpayers and tax officials, scientists and students work with the norms of the Tax Code of Ukraine. A clear understanding of them is the key to voluntary filling of the budget and high-quality tax education. Voluntary payment is possible under the condition of a systemic policy in the field of tax education, covering all levels – from preschool to higher. Fulfilling the constitutional obligation to pay taxes in full is the business of the entire people. It has been established that the central executive body implementing tax policy lacks norms for the development and implementation of measures to ensure tax security. The priority task should be the legal regulation of tax security and the protection of national interests from threats – tax evasion, the shadow economy, offshore, and fictitious enterprises. The mandatory function of this body should be legally enshrined responsibility for the state of the taxation sphere, in particular, regarding the identification, prevention, and neutralization of threats, including: 1) risks of tax legislation (terminology, principles, and tax establishment principles); 2) threats to the implementation of national interests in the field of taxation (uncertainty of policy, discretionary powers, evasion, and lack of tax education). It has been established that the primary task of the present day is to improve the legal regulation of social relations in the field of taxation, namely, to streamline the current norms of the Tax Code of Ukraine and completely abandon the use of indefinite terms and concepts in tax legislation. A study of foreign experience in preferential taxation was conducted, including in the context of decentralization.
- Research Article
- 10.59403/3h9nhwc
- Oct 17, 2025
- European Taxation
- Davide Greco
In this note, the author analyses the complex Italian tax framework governing income from the exploitation of image rights by athletes and celebrities. After outlining the main interpretative approaches that have emerged over time, it focuses on the landmark case involving Portuguese footballer Cristiano Ronaldo during his tenure at Juventus football club. The discussion concludes with an assessment of the recent amendments to the Italian Consolidated Income Tax Act and their potential impact on the taxation of image rights in the sports and entertainment industries.
- Research Article
- 10.24144/2307-3322.2025.90.5.55
- Oct 14, 2025
- Uzhhorod National University Herald. Series: Law
- T.O Holoiadova
It is indicated that the taxation system is a central component of the state financial strategy, ensuring the mobilization of resources to the state treasury and forming the economic basis for social progress. At the same time, determining the most effective model of tax regulation in Ukrainian realities continues to be an urgent task for both academic circles and practitioners. The article examines optimal taxation within the tax system of Ukraine and emphasizes that the pursuit of forming an optimally balanced taxation system in Ukraine remains relevant. It is established that the reform of the tax system under new realities must be carried out through the consistent implementation of the strategic objectives of Ukraine’s tax policy. It is also determined that Ukraine’s aspiration to join the European Union requires the harmonization of national tax legislation with the legislative requirements in the field of taxation that exist within the EU. It is noted that today Ukraine’s tax system is shaped under the significant influence of international tax competition, given the necessity of entering foreign markets. Tax policy is an extremely important factor in the effective implementation of state policy and the functioning of the state. The current tax policy of Ukraine is aimed at stimulating business development, especially small enterprises, creating favorable conditions for entrepreneurs, and ensuring stable budget revenues both for social expenditures and for financing needs. However, it faces problems of legislative instability, frequent changes in taxation rules, and the presence of numerous exemptions that undermine the principle of equality. The key directions include supporting actual owners, optimizing the balance between direct and indirect taxes, as well as enhancing the role of local taxes. Today, tax reforms are reflected in the permanent state of the tax system. Evidence of this is provided by the Tax Code of Ukraine and its continuous improvement. This is particularly relevant today, when the state, on the one hand, at the legislative level (p. 69.1, subsec. 10, sec. XX of the Tax Code of Ukraine), recognized that due to military aggression not all taxpayers are able to fulfill their tax obligations in a timely manner. On the other hand, the right to acknowledge such impossibility has been vested in the controlling authorities, which make decisions at their own discretion.
- Research Article
- 10.51473/rcmos.v1i2.2025.1471
- Oct 6, 2025
- RCMOS - Revista Científica Multidisciplinar O Saber
- Lorena Beatriz Albino Silva
This paper addresses the application of the ability to pay principle to taxes. It aims to study this principle in the Brazilian legal system, its importance for compliance with constitutional norms, and how it is applied to taxes. In this sense, the paper delves deeper into the concept and implications of taxes as a tax type, highlighting cases of exaction. Next, a study of tax principles is conducted, particularly the ability to pay principle. Finally, regarding the analysis of the ability to pay principle's application to this tax type, the paper examines the provisions of the Federal Constitution, the National Tax Code, national legal scholars, and the case law of the Supreme Federal Court to assess its effective application in these cases. Finally, considerations are made regarding the current Brazilian scenario regarding the application of the ability to pay principle to taxes and the encouragement of its application as a guarantor of equality.
- Research Article
- 10.23947/2949-1843-2025-3-3-48-53
- Oct 3, 2025
- Legal Order and Legal Values
- T V Verbitskaia + 2 more
Introduction. Amendments to the Tax Code of the Russian Federation on the implementation of the tourist tax enacted in 2025 made it relevant to find a balance between the interests of municipalities to replenish the budgets and maintain the volume of tourist flows in the context of tax burden increase on the tourism business. Scientists have studied the foreign practices of tourist tax implementation and its positive impact on the development of inbound tourism has been proved, however, no comprehensive research has been carried out on the efficiency of taxation mechanism with regard to the studied field. The aim of the present study is to analyse the acting tax legislation of the Russian Federation, as well as some municipal practices and identify the ways to improve the tourist tax implementation mechanism for maintaining the volume of tourist flows in the new conditions.Materials and Methods. The research was based on the following materials: the acting legislation of the Russian Federation, scientific studies, municipal legal acts of Ekaterinburg, and publications in the media. To determine the features of tax legislation implementation in the context of maintaining the tourist flows, the authors used the methods of teleological interpretation, modeling, structural-functional and systemic analysis.Results. It has been ascertained that for the development of the inbound tourism, the tourist tax implementation mechanism should be flexible, i.e. take into account the features of the tourist routes existing in the whole region and in the individual municipalities, as well as consider the seasonal changes. Such a comprehensive approach will require close public-private partnership aimed at implementing this tax. However, as follows from Ekaterinburg experience, cooperation between these structures is not always maintained at the proper level. It has been found that maintaining the volume of tourist flows in the context of rising costs of accommodation facilities, requires the development of the tourism infrastructure. A decrease in the volume of tourist flows due to collection of the tourist tax indicates insufficient development of the taxation mechanism in a particular region. Annual discussions of the practices used in the municipalities and regions on this matter will improve the taxation mechanism.Discussion and Conclusion. Improvement of the tourist tax implementation mechanism will prevent the tourist flow decrease, thus, help to avoid a blow to the inbound tourism. According to the authors, to achieve this goal, it’s necessary first of all to revise a list of tax concessions based on the popularity of the tourist routes and seasonal load, as well as improve the public-private partnership.
- Research Article
- 10.25148/lawrev.20.1.7
- Sep 22, 2025
- FIU Law Review
- Faith Stevelman
As people debate whether the Heritage Foundation’s Project 2025 is good policy, what’s being overlooked is that it’s likely unlawful as the work product of a charitable think tank. (Think tanks nearly always are qualified as charities under the tax code.) To reinforce think tanks’ educational mission, tax law sets rigorous content requirements for their materials. It also bans them from campaigning, sharply limits their lobbying, and prohibits their benefiting private parties. The doctrines are intended to keep think tanks charity-worthy educators, but they have not succeeded. Ironically, the failure reflects other features of tax law that incentivize using think tanks as politicized advocates. Tax law offers donors anonymity and offsets the cost of donations through the charitable deduction. And because think tanks are government-approved educators, their messaging enjoys enhanced credibility, hence often greater influence. No other advertising, lobbying, campaigning vehicle, or even other nonprofit form, confers this set of advantages. Part I lays out the paradigm of charitable education that is intended to govern think tanks’ affairs. To provide a contrast with the modern ones, it presents a portrait of old school think tanks—described as “universities without students.” Next it explores the historic difficulty of finding legal rules to define charitable education for public-facing speakers like think tanks. The factual core of the Article, Part II, describes think tanks that publish climate denial and obstruct climate-friendly laws. It is the first account of such think tanks in legal scholarship—a void that’s surprising because the phenomenon is ongoing since the 1990s. The facts reveal the need to reform think tanks’ status in tax exempt law. They also tell a story of importance in itself—how government subsidized, formally charitable actors have thwarted understanding of climate change and stymied positive law reforms. The facts provide a foundation for future research in climate law, lobbying and campaign finance, and political theory and sociology. In another scholarly first, Part III applies each of the four core doctrines for charities to think tanks. In addition to flouting the content standards for charitable education, it finds think tanks persistently benefit private persons, engage in banned campaigning, and lobby beyond their limits. This conduct all violates the legal standards for charitable educators. Accordingly, Part IV proposes that the IRS should recognize modern think tanks as § 501(c)(4) nonprofits, not charities. As § 501(c)(4)s, they could be bold advocates without violating the law. The educational speech, private benefits, lobbying, and even most campaigning limits would fallaway. No longer government-endorsed educators, they would have to earn their influence. Nor would donors receive tax deductions for gifts. Section501(c)(4)s think tanks would still provide donors anonymity, but at least politically active § 501(c)(4)s are receiving scrutiny from law reformers. The use of charitable think tanks as conduits for dark money, in contrast, has remained invisible until now.
- Research Article
- 10.1007/s10653-025-02756-7
- Sep 16, 2025
- Environmental geochemistry and health
- Sergio Adrián Salgado-Souto + 8 more
The concentrations of Potentially Toxic Elements (PTE) and the isotope composition of Pb in the soils of the Taxco de Alarcón region were analyzed to assess the impact of abandoned mine tailings on soils in this region. PTE concentrations in the soils exceeded the international recommended limits for Cd, Ni, Cu, Ba, Pb, Zn, and Mn. Additionally, phytoavailability and sequential extraction procedures values indicated the mobility of Pb-Zn-Mn and Pb-Zn-Mn-Cd, respectively, due to a high percentage in the more labile fractions. Environmental indices (e.g., EF, MPI, and RAC) revealed that the concentration of most soils is moderately to severely enriched in PTE, suggesting that erosion and dispersion of mine tailings are likely the main contributors to soil composition. Furthermore, the Pb isotope composition, combined with a Bayesian statistics-based model, indicates that mine tailings are the main source of Pb for soils. Although the soils in this mining region appear unaffected by mining waste, PTE concentrations and Pb isotope data indicate otherwise, highlighting that oxidation, erosion, and dispersion processes are impacting the soils. The geochemical features of these soils pose a danger to the environment and human health since they are often used for agricultural and livestock purposes, increasing PTE mobility into the food chain.
- Research Article
- 10.26794/2587-5671-2025-29-4-210-224
- Aug 31, 2025
- Finance: Theory and Practice
- A I Artemenkov + 3 more
The subject of study in the paper is the analysis of financial effects associated with the performance of regional airline projects from their launch to maturity, with the goal being the development of financial modeling tools to achieve the most thorough incorporation of such effects in the study context. Financial models as functional aids in optimal route planning for regional airlines have an under-explored potential, making the subject of study especially topical. The research methods utilized by the authors in the study are сash flow-based and accounting indicator-based investment project appraisal methods. These methods rely on integrated (three-statement) nominal financial modeling protocols developed at a monthly frequency and tailored for compliance with the Federal Aviation Guidelines. The resulting model provides and reconciles the derivation of free cash flows on the invested capital (FCFF) and free cash flows to equity (FCFE) under both the direct and indirect methods of cash flow derivation, thereby helping estimate the performance and efficiency of the aviation projects in a comprehensive way. It also incorporates some advanced features, such as accounting for aviation subsidies, provisioning for the overhauls of Airframes and Engines, compliance with the national Tax code and Federal Aviation Guidelines, as well as the treatment of initial Tax Loss Carryforwards. The findings of the model afford a conclusion that financial support measures in the form of existing regional airline subsidies in Russia may just about ensure a minimum acceptable rate of return on capital invested in regional airline projects. The practical significance of the model for regional airlines is in allowing them to support their business planning processes while seeking licenses, flight and subsidy approvals from Aviation Authorities, as well as actually optimize their long-term route maps and schedules with an eye to key financial parameters (e. g. ROE or NPV). In terms of research novelty, the financial model innovates algorithms to endogenize and automate the timing of repair and overhaul flags for the aircraft fleet in the context of investment depreciation and maintenance schedules.
- Research Article
- 10.12737/1998-0701-2025-11-7-27-33
- Aug 19, 2025
- Auditor
- A Klonickaya + 1 more
This article considers the topical issues of due commercial diligence by taxpayers when selecting counterparties. Particular attention is paid to the analysis of judicial practice under Article 54.1 of the Tax Code of the Russian Federation, the problem of “technical companies” and standards for checking counterparties. On the basis of letters and clarifications of the Federal Tax Service of Russia, as well as arbitration cases, key risks are identified and directions for improving due diligence activities are proposed. Conclusions are drawn as to how commercial due diligence affects risk mitigation when choosing a counterparty in order to ensure economic and tax security of business entities.
- Research Article
- 10.61345/1339-7915.2025.2.29
- Aug 11, 2025
- Visegrad Journal on Human Rights
- Kateryna Kuchyna
The pertinence of the research arises from the fact that in Ukrainian judicial case-law, at this point, the understanding has been established that the tax authority may, at its discretion, apply to the court to confirm the validity of the tax seizure both (at its discretion) under a special (urgent) judicial procedure (duration of less than 96 hours), and under the general rules of administrative proceedings (duration of which is about 60 days). There are also disagreements regarding the legal significance of the taxpayer’s disagreement with the fact that they committed a tax offense, which is the basis for the tax seizure of their property, for the possibility of confirming its validity under a special (urgent) judicial procedure. Having considered these issues, the author maintains that the short period of court resolution of applications on judicial review of tax seizure is compensated by the taxpayer’s right to further appeal the tax seizure applied to them, even after its declaration to be justified. If the justification of the tax seizure was to be confirmed within several months (according to the rules of general administrative proceedings), this measure would be completely deprived of its effect. Equally unacceptable as the article indicates is the point of view according to which the tax authority may, at its discretion, apply to the court for a judicial review of the tax seizure both under a special (urgent) judicial procedure or under the rules of general proceedings. In particular, this is due to the fact that the special (urgent) judicial procedure was devised particularly for a purpose of judicial review of tax seizure and, therefore, has a priority over the general proceedings. Additionally, the rules of general proceedings are not designed to ensure confirmation of the validity of the tax seizure within 96 hours from the moment of its application, while the absence of a court decision within this period on recognizing the seizure as justified is a basis for its termination (Article 94 (94.19) (94.19.1) of the Tax Code of Ukraine). In light of this, the author assumes that the optimal solution is to supplement the relevant provisions of the legislation on administrative proceedings with a rule that the tax authority must apply initially through a special (urgent) judicial procedure to confirm the validity of its tax seizure.
- Research Article
- 10.61345/1339-7915.2025.2.30
- Aug 11, 2025
- Visegrad Journal on Human Rights
- Oleksandr Chernenkyi
The pertinence of the research arises from the fact that in Ukrainian judicial case-law, at this point, the understanding has been established that the tax authority may, at its discretion, apply to the court to confirm the validity of the tax seizure both (at its discretion) under a special (urgent) judicial procedure (duration of less than 96 hours), and under the general rules of administrative proceedings (duration of which is about 60 days). There are also disagreements regarding the legal significance of the taxpayer’s disagreement with the fact that they committed a tax offense, which is the basis for the tax seizure of their property, for the possibility of confirming its validity under a special (urgent) judicial procedure. Having considered these issues, the author maintains that the short period of court resolution of applications on judicial review of tax seizure is compensated by the taxpayer’s right to further appeal the tax seizure applied to them, even after its declaration to be justified. If the justification of the tax seizure was to be confirmed within several months (according to the rules of general administrative proceedings), this measure would be completely deprived of its effect. Equally unacceptable as the article indicates is the point of view according to which the tax authority may, at its discretion, apply to the court for a judicial review of the tax seizure both under a special (urgent) judicial procedure or under the rules of general proceedings. In particular, this is due to the fact that the special (urgent) judicial procedure was devised particularly for a purpose of judicial review of tax seizure and, therefore, has a priority over the general proceedings. Additionally, the rules of general proceedings are not designed to ensure confirmation of the validity of the tax seizure within 96 hours from the moment of its application, while the absence of a court decision within this period on recognizing the seizure as justified is a basis for its termination (Article 94 (94.19) (94.19.1) of the Tax Code of Ukraine). In light of this, the author assumes that the optimal solution is to supplement the relevant provisions of the legislation on administrative proceedings with a rule that the tax authority must apply initially through a special (urgent) judicial procedure to confirm the validity of its tax seizure.
- Research Article
- 10.61345/1339-7915.2025.2.7
- Aug 11, 2025
- Visegrad Journal on Human Rights
- Stanislav Goza
The aim of the work is to prove, through a comparative legal analysis, the inefficiency and non-compliance with international standards of the current model for determining the tax residency of individuals in Ukraine, and to develop proposals for its legislative improvement. The methodological basis of the study includes the comparative legal method, used to analyze the legislation of foreign countries and Ukraine; the formal-dogmatic method for interpreting the norms of the Tax Code of Ukraine and the OECD Model Convention; as well as general scientific methods of analysis and synthesis to formulate the findings and proposals. Results. The study found that, contrary to common international practice, the Tax Code of Ukraine integrates a hierarchical system of tests into its national definition of a tax resident. This structure almost completely replicates the conflict-resolution mechanism (“tie-breaker rules”) from Article 4 of the OECD Model Convention. It has been proven that this approach constitutes an unjustified “self-limitation” of Ukraine’s tax jurisdiction, as the state preemptively cedes its right to tax an individual even before an international treaty is applied. This creates a significant risk of reducing the tax base for personal income tax. Conclusions. It is concluded that the current definition of a tax resident in Ukraine is inefficient and requires revision. The author substantiates the proposal to amend the Tax Code of Ukraine by removing the sequential tie-breaker rules from the domestic definition. It is proposed to establish a clear list of primary, alternative criteria (e.g., permanent home, duration of stay), which will align Ukrainian legislation with international best practices, expand the state’s tax base, and simplify tax administration.
- Research Article
- 10.33693/2541-8025-2025-21-3-38-44
- Aug 4, 2025
- Economic Problems and Legal Practice
- Maksim Yu Berezin
Purpose of the study. The modern tax process in the Russian Federation does not yet have the necessary degree of legal regulation that would fully ensure the legality and certainty of the actions and decisions of tax authorities at the stages of reviewing tax audit materials and appealing decisions made by tax authorities, of which, in the absence of reasonable grounds, decisions made in accordance with Article 101.4 of the RF Tax Code that are not subject to appeal are singled out into a separate category. Conclusions. The article proposes to establish in the tax law a specific deadline for the preparation of a tax authority decision on a taxpayer's case, oblige the tax authority to justify the reasons for missing this deadline, oblige the superior tax authority to formalize the fact of accepting the taxpayer's appeal for proceedings in a separate procedural document, introduce a new authority of the superior tax authority to terminate proceedings on the taxpayer's appeal, clarify the wording of the powers of the superior tax authority when considering the appeal on the merits, strengthen guarantees for the protection of the rights of persons brought to tax liability when appealing decisions made in accordance with 101.4 of the RF Tax Code, and introduce into the tax process a new institution for reviewing decisions of tax authorities that have entered into force under new circumstances.
- Research Article
- 10.1002/tie.70018
- Aug 1, 2025
- Thunderbird International Business Review
- Jennifer H Heckel + 1 more
ABSTRACTThis study provides valuable insight for scholars, practitioners, and government officials on how a local office of a respected international consulting firm became associated with allegations of illicit influence and state capture. The article presents how political and business leaders used a government agency, the South African Revenue Service (SARS), to gain power, amass wealth, and find protection from prosecution. It outlines how illegal actions by public officials sworn to uphold justice and the rule of law harmed the Republic of South Africa. It also examines how a consulting firm that values integrity and trustworthiness contributed to questionable decisions by state officials. The impact at SARS included: bypassing government procurement procedures; restructuring and staffing that dismantled tax code enforcement; distributing public funds into private hands; and avoiding public accountability. The study concludes with a synopsis of the multiple investigations and implications for ethical behavior in an era of institutionalized state capture.
- Research Article
- 10.54648/ecta2025033
- Aug 1, 2025
- EC Tax Review
- Pedro Petiz Viana
The Portuguese legislation on the taxation of imported used vehicles has led to a continuous interplay between the European Commission, the European Court of Justice, and the national legislator. The Portuguese national budget for 2025 brings us the latest development on this matter, with several amendments to the Vehicle Tax Code coming into effect on the 1 January 2025. With this latest legislative amendment, the Portuguese legislator has been successful in eliminating the discriminatory taxation of imported hybrid vehicles from the European Union. However, this legislative solution will result in situations of ‘reverse discrimination’, since domestic vehicles will be subjected to less favourable taxation rates than vehicles imported from the European Union.
- Research Article
- 10.24144/2307-3322.2025.89.2.59
- Jul 29, 2025
- Uzhhorod National University Herald. Series: Law
- O V Hlukh
The article examines the legal principles of tax credit formation in the value added tax system as one of the key elements of the modern fiscal mechanism. It is argued that the tax credit performs not only the function of reducing tax liability, but also indirectly contributes to maintaining the financial stability of taxpayers. It is substantiated that the legal nature of the tax credit consists in temporary indirect crediting of the state by the taxpayer, which is implemented by paying value added tax as part of the price of purchased goods or services. It is proved that the effective implementation of the right to a tax credit is possible only in the presence of clearly drawn up supporting documents, namely tax invoices registered in the Unified Register of Tax Invoices. Special attention is paid to the analysis of Articles 198 and 201 of the Tax Code of Ukraine, which determine the conditions, grounds, terms and procedure for including value added tax amounts in the tax credit. It is concluded that to ensure transparency and legal certainty in the field of tax credit, a clear regulatory regulation of the grounds for its application, forms of documentary confirmation and terms of exercising such a right is necessary. Attention is also drawn to the problem of applying the cash method when determining the moment of occurrence of a tax credit, as well as to issues related to adjusting the tax credit in the event of errors in tax reporting. As a result, conclusions are formulated on improving the current legislation in terms of tax credit formation in order to increase the efficiency of value added tax administration and protect the rights of taxpayers. It is concluded that the legal principles of tax credit formation in the value added tax system constitute a set of regulatory and legal provisions that regulate the procedure, conditions and grounds for including value added tax amounts in the taxpayer’s tax credit. It is proposed to include the following legal principles for the formation of a tax credit in the value-added tax system: 1) the presence of the status of a value-added tax payer - a tax credit is formed exclusively by value-added tax payers registered in accordance with the established procedure in accordance with the provisions of the Code of Ukraine; 2) the tax credit includes the amounts of tax paid/accrued in the event of transactions specified in the exhaustive list in Article 198 of the Code of Ukraine; 3) documentary confirmation - the basis for the formation of a tax credit is a properly executed tax invoice registered in the Unified Register of Tax Invoices, as well as other documents specified by law (customs declarations, invoices, etc.); 4) the tax credit for the reporting period is determined based on the contractual (contractual) value of goods/ services and consists of the amounts of taxes accrued (paid) by the taxpayer at a rate determined from the tax base in accordance with the procedure specified by the Code of Ukraine.
- Research Article
- 10.24144/2307-3322.2025.89.2.68
- Jul 29, 2025
- Uzhhorod National University Herald. Series: Law
- P V Kolomiiets
The article is devoted to the analysis of the impact of the repeal of the Economic Code of Ukraine on the state of economic and tax security of the state, namely, the study is aimed at identifying potential risks and threats that may arise due to the lack of coordination between the reform of economic legislation and the current tax system, as well as at the formation of scientifically based proposals for maintaining the functional stability of the tax and financial system of Ukraine in wartime conditions and subsequent reconstruction. The paper reviews the Law of Ukraine No. 4196-IX of January 9, 2025, which establishes August 28, 2025, as the date when the Commercial Code ceases to be in force. It is argued that the Code has played a fundamental role in the legal regulation of commercial relations for over two decades, ensuring a balance between public and private interests, defining the state’s participation in the economy, and shaping market governance. In the context of martial law and economic instability, commercial legislation must remain an instrument for supporting economic resilience. It is noted that, although amendments were introduced to 47 legislative acts, no changes were made to the Tax Code of Ukraine, which creates risks of disconnection between the new commercial legal framework and the existing tax regulation model. The paper analyzes the classification of Ukrainian legislation and the legal positions of the Constitutional Court of Ukraine, where commercial law is recognized as a separate legal branch. The conclusion is made about the need for a comprehensive review of the regulatory framework, synchronized with the strategic priorities of national security, in particular in terms of tax security as a financial guarantor of the state’s stability in conditions of war and post-war reconstruction, since insufficient integration of new approaches to regulating economic activity with financial and tax mechanisms can lead to a decrease in the efficiency of the tax system, losses of budget revenues, and a weakening of the state’s ability to finance its strategic functions. It was emphasized that the comprehensiveness, systematicity, and strategic validity of legislative changes should be the key to preserving the economic potential and strengthening the tax security of Ukraine.
- Research Article
- 10.24144/2307-3322.2025.89.2.60
- Jul 29, 2025
- Uzhhorod National University Herald. Series: Law
- S V Goza
This article investigates the theoretical and practical aspects of determining a state’s tax jurisdiction within the context of contemporary globalization processes and international tax relations. The relevance of the topic is driven by the increasing intensity of cross-border economic transactions, which gives rise to complex legal relationships where the classic understanding of state sovereignty, closely tied to physical territory, proves to be insufficient. The author analyzes the approaches of Ukrainian scholars to the definition of «jurisdiction» and identifies an internal contradiction when applying them to the tax sphere, which inherently extends beyond state borders. The purpose of the article is to refine the theoretical approach to defining tax jurisdiction and to develop a practical model for its application under the conditions of double taxation treaties. To achieve this goal, general scientific and special methods of cognition were used, including systemic, comparative-legal, and historical-legal analysis. The paper substantiates that tax jurisdiction should be defined not through territorial boundaries but through the concept of economic allegiance of a person to a state. This allegiance is realized through two fundamental principles: the residence principle, which extends jurisdiction to all residents of a state with respect to their worldwide income, and the source principle, which extends jurisdiction to non-residents with respect to income derived from the territory of the state. It is confirmed that this approach is implemented in the Tax Code of Ukraine, corresponds to the legislation of leading foreign countries (USA, UK, Germany), and has a deep historical foundation laid in the works of the Financial Committee of the League of Nations in the 1920s. Special attention is given to the problem of international legal double taxation as an inevitable consequence of the overlap of tax jurisdictions of different states. It is proven that the primary instrument for its resolution is bilateral treaties, which establish mechanisms for the voluntary self-limitation of states’ tax sovereignty. The scientific novelty of the article lies in the development and substantiation of a two-level algorithm for applying tax legislation in the presence of an international treaty. At the first level, the base tax liability is determined solely based on national legislation. At the second level, the international treaty acts as a corrective mechanism that limits, modifies, or cancels the state’s taxing rights determined at the first level. This algorithm systematizes law enforcement practice and ensures legal certainty for all participants in legal relations.
- Research Article
- 10.59403/3p3t32t
- Jul 24, 2025
- European Taxation
- Khatuna Kharkhelauri + 4 more
This article analyses the effects of amendments to Georgia’s Tax Code on its economy and foreign investment. The measures streamlined compliance, diminished administrative expenses, enhanced transparency and curtailed tax evasion, thus augmenting investor trust. This catalysed enhanced foreign investment, generated employment, expanded GDP, encouraged the formation of small and medium-sized enterprises, diversified the economy and increased social stability, providing a reproducible framework for other transition economies.
- Research Article
- 10.31866/2709-846x.2.2024.335892
- Jul 23, 2025
- Socio-Cultural Management Journal
- Nataliia Mohylevska + 3 more
Introduction. The relevance of the research topic is due to the problems caused by the globalisation of society. The modern creative industry is going through a new digitalisation stage, transforming its content, organisational and stylistic components. Purpose and methods. The purpose of the article is to analyse the problems and prospects of using blockchain technology in the creative industry of Ukraine. The methodological basis of the study is a systemic-functional, dynamic, comprehensive principle that includes methods of analysis and synthesis, modelling, historical and logical methods, and statistical analysis. Results. The article reveals the specifics of managing socio-cultural projects using blockchain and identifies the positive and negative results of its application. The scientific novelty of the research results is to reveal the socio-cultural essence of managing socio-cultural projects by using blockchain, identifying its positive features, negative consequences and threats to the artist and the user. Conclusions. The author analyses the legislative framework for the use of digital tools in the creative industry, in particular, the Law of Ukraine ‘On Culture’, the Law of Ukraine ‘On Virtual Assets’, the Law of Ukraine ‘On Amendments to the Tax Code of Ukraine and Other Legislative Acts of Ukraine Regarding the Regulation of the Turnover of Virtual Assets in Ukraine’, and assesses the legal regulation of blockchain technologies in the field of socio-cultural activities. The author assesses the level of blockchain development in the creative industry of Ukraine in the context of the war, and considers financial aspects, including the urgent need for investment and state support for blockchain-related projects.