Tax Security Research Articles

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.

With an increase in the basic income tax rate from 2025, organisations are faced with the task of ensuring the tax security of profit taxation in the context of innovative economic development, allowing taxpayers and tax authorities to effectively use innovative technologies in their activities. The purpose of this article is to find tools that can be used to optimise the profit taxation process and increase tax security. The subject of the study are investment tax deductions and ensuring economic security when applied in the context of innovative economic development. The focus of this article is on investment tax deductions as the most complex tools to reduce corporate income tax. The article uses methods of a systematic approach, analysis, and synthesis. As a result of the conducted research, it has been concluded that an individual approach by taxpayers is necessary in terms of the possibility and expediency of applying investment tax deductions, realistically assessing potential risks and tax savings. Using the example of specific paint and varnish industry organisations, calculations have been performed that allow taxpayers to make effective management decisions and ensure tax security. The presented calculations can be applied by organisations of various fields of activity. The authors have concluded that the criteria requirements for the use of investment tax deductions limit the practice of their application. The results of the study can be used in developing solutions to ensure tax security in the taxation of corporate profits. The conclusion is made about the need for further development of incentives for investment activities of organisations.

Using the example of the regions of the Volga Federal District, an analysis of the state of their investment development as well as the volumes of tax revenues to various levels of the budget system, was carried out in order to identify opportunities to ensure financial self-sufficiency of territories under different scenarios. The results of the study show that regions, even within one federal district, have significant differentiation both in terms of the level of specific tax revenues and in terms of the volume of investment in fixed capital per capita. At the same time, the correlation and regression analysis of these indicators revealed the presence of a close relationship between them. The main reasons for the disproportions in the level of tax security of the regions were established. Firstly, the preservation of raw material rent as the largest source of tax revenues to the consolidated budget of the Russian Federation and the extreme unevenness of its distribution due to differences in the structure of regional economies; secondly, the allocation of the overwhelming share of revenues from the mineral extraction tax to the federal budget; thirdly, the initial insufficiency of the volumes of state (budget) support for the development of high-value added production and the need to use long-term credit mechanisms for financing in order to subsequently increase the share of taxes from the manufacturing sector. An assessment of the financial self-sufficiency of the territories under various scenarios for the distribution of tax revenues was carried out and proposals were made for its increase at the regional level.

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.

The Constitution of Ukraine regulates only one, single taxation system. The Constitution of Ukraine does not mention the plurality of taxation systems. However, by the Decree of the President of Ukraine dated 03.07.1998 No. 727/98, another taxation system was introduced – a simplified one, which was intended to facilitate business, in particular for small and medium-sized businesses. At the same time, in modern conditions, the simplified taxation system raises concerns about its impact on the tax security of the state. Tax security is a component of the country's economic security and provides for timely, full and stable receipt of tax payments to budgets of all levels. However, there is an opinion that the current mechanisms for the functioning of the simplified taxation system create certain gaps in the taxation system, which may contribute to tax evasion, reduce fiscal efficiency and threaten the stability of the budget system. In this regard, the need for a systematic review of the principles of the functioning of the simplified taxation system is becoming more urgent in order to ensure its compliance with the principles of tax security, which may include reforming or even eliminating this system.

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.

Налоговое администрирование рассматривается как часть управления налоговой системой, несмотря на то, что оно реализуется контрольно-надзорными органами в виде исполнения принятых законодательных норм. Налогообложение имущества организаций и физических лиц является важнейшим элементом управления налогового администрирования на региональном уровне. В статье предлагается комплекс мероприятий по предупреждению образования налоговой задолженности по имущественным налогам и ее минимизации. Отмечается, что снижение налоговых поступлений создает риск дестабилизации социально-экономического развития регионов, то есть возникает экономическая угроза. Предлагается модель влияния имущественного налогообложения на устойчивое развитие экономики региона, важным элементом которой является налоговая безопасность. Tax administration is considered as part of the tax system management, despite the fact that it is implemented by supervisory authorities in the form of enforcement of adopted legislative norms. Taxation of property of organizations and individuals is the most important element of tax administration management at the regional level. The article proposes a set of measures to prevent the formation of tax arrears on property taxes and to minimize them. It is noted that a decrease in tax revenues creates a risk of destabilization of the socio-economic development of regions, that is, an economic threat arises. A model of the influence of property taxation on the sustainable development of the regional economy is proposed, an important element of which is tax security.

The article examines extraordinary tax and legal measures ensuring Russia's economic security amid contemporary challenges. The research focuses on public relations regarding extraordinary taxes and fees collection and stimulating tax measures application. The study analyzes legal norms regulating extraordinary tax measures introduced during the COVID-19 pandemic, anti-Russian sanctions regime, and partial economic mobilization. The article evaluates Russian tax law's capacity for adaptive extraordinary response to diverse national economic security threats. Special attention is given to systematizing and classifying extraordinary tax measures across three challenge groups: pandemic restrictions, sanctions pressure, and partial economic mobilization needs. The methodology employs general scientific methods (analysis, synthesis, induction, deduction) and specialized approaches: systematic legal analysis, historical-legal and formal-juridical methods. The scientific novelty lies in theoretical-methodological conceptualization and systematization of extraordinary tax-legal measures under complex contemporary threat conditions. The work presents an original definition of extraordinary tax security measures as specialized tax-legal instruments of temporary or permanent nature, applied by the state responding to emergencies and external challenges. The research develops a classification of extraordinary anti-pandemic tax measures into: socially oriented measures; tax rate and mandatory payment tariff adjustments; project-oriented stimulating measures; liberalization of tax control and supervision activities. The study proposes a dual approach to sanctions countermeasures through tax policies and substantiates the dualistic nature of tax-legal regulation under partial mobilization economy conditions. A identified trend shows gradual transformation of extraordinary tax measures into permanently operating tax regulation mechanisms with corresponding content and form adjustments. This research contributes to understanding how tax law can adaptively respond to multifaceted security challenges while maintaining economic stability.

The article investigates the impact of low tax jurisdictions certain countries in the European Union on the economic security of the state. The author analyzes the relationship between the tendency to withdraw revenue to low tax jurisdictions and the tasks of ensuring the sovereignty of the state, including fiscal risks of states. Based on the definition of tax jurisdiction as the power under national legislation to impose tax levies through its fiscal authorities, the authors discuss the essence of this concept and its relationship to the tax liabilities of individuals and legal entities. The author examines known examples of capital withdrawals to low tax jurisdictions within the European Union and their impact on the state's economy. The article highlights the phenomenon of offshore as an instrument of unfair tax competition. The author provides different perspectives on the conceptual apparatus of the term definition of offshore, discussing its impact on the international economy and emphasizing the negative aspects of unfair tax competition of individual EU countries. Based on the definition of offshore as territories or countries that establish a preferential tax regime, the author analyzes the privileges available to offshore companies, such as simplified reporting and confidentiality of business owners' data. The negative aspects of unfair tax competition stemming from the use of offshore are discussed in order to identify their potential threats to the economic stability of states. The analysis of offshore practices within the EU complements the context of the discussion of the role of offshore in the overall context of the world economy. This emphasizes the diversity of offshore practices and the impact on global tax strategies and financial policies. The author leads to the conclusion about the direct impact of European offshorization processes on the tax security of the Russian Federation.

The paper proves that ensuring the tax security of the state is a necessary condition for the realization of its fiscal interest, which requires effective management of the tax system, improvement of tax control and increased responsibility for violations of tax legislation. It is substantiated that a comprehensive approach to the development of the budget and tax policy will ensure financial stability, support the development of the economy and promote the integration of Ukraine into the European economic space. It is shown that in EU countries great attention is paid to transparency of budget and tax legislation, digitization of budget and tax processes and cooperation between states in the field of budget and tax policy. It was established that budget and tax security is an important component of the economic security of the state. It provides for the country's ability to ensure stability and efficiency in the management of public finances and tax systems, which is the basis for sustainable economic development and protection of national interests. It was determined that budget and tax security is aimed at creating such conditions that ensure the stability of the national economy, increase its ability to respond to external and internal economic challenges, and also ensure the effective functioning of the state's financial system. It has been established that budget security is an important component of the state's economic security, which includes the state's ability to ensure stability and effective management of budget resources, as well as to maintain financial stability at the national level. It assumes that the state budget should be able not only to cover the current needs of the state, but also to ensure sustainable economic growth and minimize financial risks. It is shown that ensuring tax security in Ukraine is a complex process that includes the creation of a stable, fair, transparent and effective tax system that meets both the interests of the state and the needs of businesses and citizens. Ways to improve the main mechanisms of the state's budget and tax security are proposed: stability of the state budget, transparency in the budget process, effective use of budget funds, financial stability and ability to adapt, fight against shady practices, support of social standards, international cooperation.

The subject. The norms of Russian legislation governing risk management systems in the implementation of various types of public control.The purpose of the study is to confirm or refute the hypothesis that different types of public controls affect the tax security of the state, and tax risk management systems should be coordinated in their implementation.Methodology. The author uses methods of system analysis of scientific papers devoted to the various types of public control. Formal logical and legal interpretation of Russian regulatory legal acts is used also.The main results. The impact of tax, customs, currency control, AML/CFT control and other types of public control on ensuring the tax security of the state is substantiated. The interrelation of the existing tax risk management systems of the state in Russia in the implementation of these types of control is revealed.Conclusions. It is necessary to uniformly fix the basic principles of risk management in the regulations governing the grounds and procedures for such public control, ensuring tax security of the state. These principles include: the obligation to identify, assess, and systematize risks and other threats, describe indicators, categorize management objects accordingly, and correlate adopted regulatory and individual legal acts with the goals of preventing the occurrence and/or minimizing of the harmful effects of a particular risk or threat.

The role of taxes as a factor of economic security depends on the specific situation, peculiarities - the development of the country, which it is experiencing, the nature of the economic policy pursued, the stability of state power. The tax system, acting simultaneously as a factor of economic security, should contribute to ensuring such development of the economy, which would create the necessary financial conditions for socio-economic stability and development of the state and each region, preserving the integrity and unity of the financial system (including monetary, budgetary, credit, tax and currency systems), successfully countering internal and external threats to Kyrgyzstan and its regions In modern economic conditions any state pays special attention to such phenomena as tax evasion, because they have a negative and sometimes threatening impact on the economy, significantly affect the state of economic and national security of the state. The tax component of economic security, its role and importance in the conditions of modern economy are becoming particularly relevant. This is due to the large number of violations in the field of taxation, arrears of tax payments to budgets of all levels, as well as the presence of a significant amount of the shadow sector of the economy. These circumstances represent a significant problem for the state both from the point of view of ensuring and strengthening tax security, and from the point of view of economic stability of the state as a whole. The most important element of economic security of the country in modern conditions is tax security. Taxation is a link between the economy and the budget system, which redistributes funds between economic entities, individuals and the state.

The article considers the impact of sanctions restrictions on the economic condition of enterprises operating in different sectors of the economy to identify the most affected new challenges of industries that need to be provided with tax incentives. The indicators of tax security of the state are analyzed, for example, the growth rate of tax revenues from enterprises in 2023 compared to 2022. etc. The subject of the study is the activities of organizations under sanction restrictions in 2022-2023. The author analyzed data on companies engaged in 45 types of economic activities. The study employed economic-statistical, graphical, and multivariate statistical methods, allowing differentiation of economic sectors based on the level of impact of sanction restrictions. The novelty of the research lies in the typology of economic sectors based on clustering according to the degree of influence of sanction restrictions using multivariate statistical methods. Five clusters were identified and scientifically substantiated. Suggested directions of improvement of tax incentives of branches of the economy. The scientific novelty of the study is the typology of economic sectors based on clustering according to the degree of influence of sanction restrictions using multivariate statistical methods. The author selected and analyzed indicators that allow for the consideration and assessment of the economic, tax, and investment potential of enterprises operating in various sectors of the economy to determine the degree of impact of external economic and internal conditions on their state in the context of new challenges to tax security. The main conclusions of the study are: a) the existence of significant differentiation in the level of impact of sanction restrictions on the economic situation of sectors; b) despite the overall increase in tax revenues and the rising number of profitable enterprises in Russia, several sectors of the Russian economy are significantly lagging in terms of development, partly due to the effects of sanctions; c) several sectors require additional measures aimed at minimizing the impact of threats to tax security.

In this study, the authors consider the issues of tax security of enterprises and related tax risks. Their classification is given. An overview of modern tax risk management tools of the enterprise is given. The importance of predictive analysis in enterprise risk management processes is shown. A four-stage tool for minimizing tax risks of an enterprise based on forecasting has been developed, which allows managing the tax security of an enterprise.

The article is dedicated to the role and place of fiscal policy in the system of regulating socioeconomic development under modern conditions. The aim of writing the article is to reveal and deepen the theoretical and methodological foundations of implementing the tax component of fiscal policy in the system of financial and economic relations. Theoretical approaches to disclosing the categorical content of tax policy as a process of planning and collecting revenues for budgets of various levels through constant sources of tax revenues are generalized. A list of the main components of the mechanism of tax regulation of socioeconomic development is defined. The necessity of assessing the profile of the implemented financial regulatory policy, based on the compositional structure of the tax system and the level of fiscal burden, is emphasized. The significance of the levels of tax burden, defined as the share of the sum of tax revenues of the consolidated budget and social contributions in GDP, in the OECD member states during the period 2014–2023 is analyzed. It is been proved that excessive fiscal burden leads to a decrease in savings and investment rates, causing a capital outflow from the respective national economies. The necessity of optimizing the ratio of tax burden levels across groups of taxpayers-individuals and legal entities has been emphasized. Under the conditions of martial law, a category of tax security within the public finance system has been allocated, characterizing a certain configuration of the fiscal space where the State’s financial demands are balanced with the interests of taxpayers in the short, medium, and long term. It is underscored that the level of fiscal burden is significant but not an ultimate criterion for assessing the profile of the tax policy implemented by the government. The fundamental importance of dividing the fiscal policy instruments in terms of their impact on the dynamics of economic growth processes has been underlined. It is indicated that tax policy should meet the principles of fiscal sufficiency, social justice, adaptability, economic efficiency and fairness, stability, and neutrality.

This scientific article is aimed at studying the features of tax compliance in tax administration within the framework of on-site and on-site tax audits, the main stages and procedure for conducting on-site and on-site inspections are considered; the dynamics of tax revenues and the results of the control work of tax authorities for 2020–2024 in the budget of the Rostov region are investigated and measures for higher efficiency and effectiveness in the activities are proposed tax authorities and in tax administration in order to ensure tax security.

This study is devoted to a comparative analysis of different models of the risk-based approach used in tax administration in the BRICS countries. The risk-based approach is widely recognized as the fundamental basis for defining and legally consolidating the tasks of tax administration bodies in modern conditions. According to this approach, the objectives of the tax administration are to identify, prevent and minimize threats to tax security in the course of the implementation of the full range of administrative functions in the tax sphere, as well as to work towards overcoming the consequences of the realization of threats. The authors propose the following points for conducting a comparison of the BRICS countries using tax risk assessment: the implementation of risk assessment in the practice of tax administration and the quality of its legislative regulation, the impact of risk indicators on the behavior of taxpayers and the impact of risk indicators on the effective implementation of tax control measures. In general, there is a high degree of similarity among all aspects of the risk-based approaches adopted in the BRICS countries. However, the methods of implementation and levels of legal certainty in laws differ from country to country.

Accurate classification of import and export goods’ Harmonized System (HS) codes is essential for ensuring tax security. Applying text classification technologies for HS code classification can significantly enhance the prevention and control of customs tax risks. However, the goods text is a semi-structured one that involves multi-domain Chinese professional vocabulary, which poses challenges for current classification models. These models often suffer from inadequate text representation and imprecise feature extraction. To address these challenges, we propose a novel classification model ERNIE-BiLSTM-Channel attention–Spatial attention (EBLCS). This model integrates ERNIE (Enhanced Representation through Knowledge Integration) with a Bidirectional Long Short-Term Memory Network (BiLSTM) and employs multi-scale attention mechanisms. The ERNIE-BiLSTM model provides a more comprehensive and accurate representation of the goods text, effectively capturing the global features of the text. By introducing channel attention and spatial attention mechanisms, greater weights are assigned to important words and word embedding dimensions, significantly enhancing the model’s ability to perceive key information. The experimental results on a customs dataset demonstrate that the EBLCS model consistently outperforms various baseline models across all evaluation metrics, effectively enhancing the performance of HS code classification.

В статье показана необходимость выявления и нейтрализации налоговых рисков организации в целях обеспечения ее налоговой безопасности. Приведены источники возникновения налоговых рисков, их классификация и основные этапы процесса управления ими. В целях предотвращения ситуаций, вызывающих возникновение налоговых рисков, предлагаются варианты внедрения налогового комплаенса в систему внутреннего контроля и управления организации. Приведенный алгоритм управления налоговыми рисками может применяться экономическими субъектами для организации системы налоговой безопасности. The article shows the need to identify and neutralize an organization's tax risks in order to ensure its tax security. The sources of tax risks, their classification and the main stages of the process of managing them are given. In order to prevent situations that give rise to tax risks, options for introducing tax compliance into the internal control and management system of the organization are proposed. The given tax risk management algorithm can be used by economic entities to organize a tax security system.

At the present stage, the analysis of the impact of taxation on the activities of enterprises and the state is becoming increasingly important in the tax area. The emergence of a fundamentally new model of relations between market participants within the framework of tax relations has led to the emergence of new tasks in the field of taxation that require taking into account the tax component when developing management decisions, the issue of tax security as a state of protection of the economic interests of taxpayers, the state and society as a whole guarantees compliance with tax legislation by all participants in tax relations. Fair and impartial tax administration, protection of the rights and legitimate interests of taxpayers, ensuring budget revenues at the level necessary to perform the functions of the state. Ensuring tax security is a complex task that requires continuous improvement of the tax system, professional development of tax authorities' personnel, and cooperation with taxpayers.The study revealed that tax security is a key element of the financial security system, ensuring the stability and development of all its components. Taxes serve as the primary source of the state's financial resources, necessary for meeting socially important needs and maintaining societal well-being. Ineffective tax policies can lead to the growth of the shadow economy, resulting in budgetary losses and reduced social stability. The tax security mechanism includes legal, organizational, and economic measures to timely detect and prevent tax risks and crisis phenomena. Important aspects are compliance with legislation, effective tax administration, and international cooperation. This approach helps maintain economic security and minimize risks in the context of globalization.