Adaptation of tax legislation to the digital economy
Abstract
The article is devoted to the study of the theoretical and legal foundations for adapting Ukrainian tax legislation to the conditions of the digital economy and transformations caused by the development of digital technologies and the emergence of new value creation models. The paper analyzes changes in the structure of economic activity, in particular the growing role of intangible assets, remote forms of service provision, platform interaction, and high capital mobility, which complicate the application of traditional categories of tax law. The article examines the problems of determining tax jurisdiction in the context of “economic presence without physical presence” and the need to clarify approaches to establishing tax ties. The article highlights international trends in tax reform in the digital environment, in particular the Pillar One and Pillar Two concepts within the OECD/BEPS initiatives aimed at redistributing tax rights between jurisdictions and introducing a global minimum tax rate. The impact of these approaches on national systems is analyzed, including the requirements for harmonizing substantive and procedural law. At the level of Ukrainian legislation, regulatory acts that form the basis for the development of the digital economy are considered, in particular, the Law of Ukraine “On Stimulating the Development of the Digital Economy in Ukraine” and the special regime “Diy.City.” The article separately examines the peculiarities of taxation of electronic services provided by non-residents, the procedure for their registration as VAT payers, problematic aspects of administering such transactions, and the need to unify procedures. The article also analyzes the directions of development of tax transparency and reporting of digital platforms based on a model of rules similar to the European DAC7 directive. The role of digital tools in the modernization of tax administration is outlined, including the introduction of e-invoicing, SAF-T, electronic services, and the use of analytical technologies to identify risky transactions. In summary, the adaptation of the tax system to the digital economy requires a comprehensive update of material, procedural, and institutional norms, harmonization with international standards, and the formation of an effective tax administration infrastructure. The article reflects key trends, challenges, and possible directions for further improvement of Ukraine’s tax policy in the context of digital transformation.
Fields of Study & Subjects
Taxation and Legal Issues
Digital Transformation in Law
Corporate Taxation and Avoidance
Publication details
- Journal / source
- Uzhhorod National University Herald Series Law
- Volume
- 3
- Issue
- 92
- Pages
- 170–176
- Publication date
- 23 January 2026
- Language
- UK