№ 4 (2025)
Articles
Tax barriers to effective business interaction in the EAEU
Аннотация
This article is devoted to the identification of tax barriers in the EAEU countries. The purpose of the scientific research is to identify modern tax barriers to effective interaction of business entities in the Eurasian Economic Union countries, as well as to propose possible options for their elimination. The object of the study is economic relations in the sphere of movement of goods, works and services within the Eurasian economic space. The subject of the study is tax barriers to interaction of business entities in the Eurasian Economic Union countries. The article identifies the following tax barriers: (1) problems of the mechanism for determining the customs value of goods; (2) problems of double taxation and non-taxation in trade within the Eurasian Economic Union member states; (3) disproportions in excise rates on alcohol and tobacco products. Each of these problems is disclosed with specific practical examples. The study is conducted using a qualitative methodology. The identified results are presented in tabular and graphical forms, which simplifies the perception of the article. The author's main contribution to the study of the topic is the proposals for the elimination of tax barriers within the EAEU. The scientific novelty consists in the formation of the following proposals for improving tax policy: (1) creation of a database of prices for imported products, as well as an electronic database of court decisions on matters of determining customs value; (2) adaptation of Articles 148 and 174.2 of the Tax Code of the Russian Federation to the content of Appendix No. 18 of the Treaty on the Eurasian Economic Union; (3) development of forms and methods of border tax and customs control, tightening of sanctions at the level of national legislation.
Taxes and taxation. 2025;(4):1-13
1-13
Tax incentives for ensuring technological sovereignty.
Аннотация
This article is devoted to the study of tax incentives for ensuring Russia's technological sovereignty. The aim of the research is to identify shortcomings in the system of tax incentives for investments and innovations and to suggest possible options for improving tax legislation. An important aspect of the work is the analysis of foreign and domestic studies regarding the effectiveness of tax incentives for ensuring technological sovereignty, as well as the advantages and disadvantages of different types of support. The article examines the existing measures of tax stimulation in the context of the technology life cycle and pays special attention to the role of technological ecosystems in creating innovations. The author emphasizes the need to stimulate not only expenses on research and development but also revenues and expenditures related to the commercialization and implementation of technology, to effectively navigate the "valley of death" that many technologies face due to the complexity of transitioning from the research stage to successful innovation. The main research methods used are analysis and synthesis, analogy and description, induction and deduction. The novelty of the research lies in identifying problems in the current mechanism of tax incentives and formulating proposals for possible changes in tax legislation to enhance the effectiveness of indirect support for ensuring Russia's technological sovereignty. The study concludes that there is a "discrepancy" in the provision of tax incentives for innovations, as many special measures are focused on the stages of creating innovations, while their commercialization and dissemination do not receive adequate attention in tax regulation, which necessitates adjustments to the tax tools. Furthermore, it discusses the ability of technological ecosystems to create additional effects in terms of innovative development and, consequently, the importance of the impact of tax benefits on all entities within the ecosystem for greater efficiency in achieving the country’s technological sovereignty.
Taxes and taxation. 2025;(4):14-25
14-25
Realizing the Fiscal and Regulatory Potential of Corporate Income Tax
Аннотация
The subject of this study is the fiscal and regulatory possibilities of corporate income tax, its structural elements, and their impact on the economic activity of business entities. The purpose of the study is to identify possible ways to expand the use of the fiscal and regulatory potential of corporate income tax as an important tool for stimulating economic activity. The paper provides an assessment of the level of corporate income tax revenues to the budget system of the Russian Federation, and analyzes the factors constraining the realization of its fiscal potential. Special attention is paid to the analysis of corporate income tax revenues based on the materials of one of the subjects of the Russian Federation with a low level of production and investment potential in the Republic of Dagestan. The conclusion is that despite the excess of the growth rate of income tax to the budget over the overall growth of tax revenues, the potential for increasing budget revenues due to an increase in the tax burden has been exhausted. Considerable attention is paid to the instruments for stimulating investment activity provided for by the current tax legislation on corporate income tax. The need to achieve the set research goal led to the expediency of using a set of different methods and techniques: the transition from the general to the particular, logical inference, observation, generalization, systematization, comparison, factor analysis, synthesis, and a systematic approach. The research is based on official analytical data from the Federal Statistics Service of the Russian Federation, the Federal Tax Service of Russia, as well as the Office of the Federal Tax Service of Russia for the Republic of Dagestan. The scientific novelty of the study lies in developing a set of recommendations to realize the fiscal and regulatory potential of income tax, thereby stimulating investment activity among organizations and reducing tax risks. The conclusion is substantiated that it is necessary to achieve an increase in corporate income tax revenues not by increasing the fiscal burden, but by fully realizing its regulatory potential as a tool to stimulate economic activity. Recommendations are formulated to improve the investment tax deduction for corporate income tax, aiming to stimulate the renewal of worn-out fixed assets. It is noted that strategically important internal reserves for increasing income tax revenues can be both the growth of the tax base due to the intensification of economic activity of the subjects of the Russian Federation, and comprehensive solutions aimed at reducing tax risks.
Taxes and taxation. 2025;(4):26-35
26-35
Public oversight of tax authorities in the government of Russia: problems of defining the limits of execution.
Аннотация
The present article is devoted to the public-legal analysis of the problems of defining the limits of public control over tax authorities of the state power in the Russian Federation. The activities, acts, and decisions of tax authorities are classified by the legislation on public control as objects of public control. However, the implementation of public control measures concerning the specified object has certain limits, conditioned, on the one hand, by the specifics of the activities of this type of public authority, and on the other hand, by the characteristics of the information they receive from taxpayers. In this regard, the scientific article formalizes and analyzes the main problems related to determining the optimal boundaries of public control concerning the activities, acts, and decisions of tax authorities in the Russian Federation. This article employs a number of scientific research methods, in particular: formal-logical; comparative-legal; historical-legal; statistical; sociological. To address the aforementioned problems, the work develops and justifies a system of measures by: a) supplementing the Tax Code of the Russian Federation with a separate article (or group of articles) that will establish the mechanism for organizing and conducting public control over the activities, acts, and decisions of tax authorities, including the regulation of issues related to the limits of its implementation; b) developing and adopting a separate Federal Law "On Public Tax Control," which will define the concept, principles, goals, objectives of public tax control, the main forms and types of its activities, and the aforementioned mechanism for their organization and implementation; c) developing a system of special requirements for representatives of entities of public control authorized to organize and conduct the aforementioned public control measures; d) creating specialized entities of public control designed to implement these measures, which will be independent of the state tax authorities.
Taxes and taxation. 2025;(4):36-45
36-45
Digitization of Value Added Tax Payment Control using Artificial Intelligence: Problems and Prospects
Аннотация
The author analyzes the problems arising from the digitalization of value-added tax (VAT) payment control using artificial intelligence. The economic and legal nature of VAT is examined, its role in forming the income part of the federal budget, the differences between VAT and the sales tax applied in several foreign jurisdictions, as well as modern trends in using the software complex ASC VAT – 2 for VAT payment control. The problems of legal regulation concerning the use of the ASC VAT – 2 software complex in tax control are identified. An examination of current judicial practices related to the use of data obtained from the ASC VAT – 2 software complex in proving taxpayer tax offenses has been conducted. This research utilized general scientific methods (dialectical method of scientific cognition, systematic method, methods of analysis, synthesis, generalization, induction, deduction, observation, explanation, interpretation, and classification, description of concepts and terms) and special legal methods (in particular, the formal-legal method). The research established that the data obtained from the ASC VAT – 2 software complex is used by tax authorities to identify and prevent tax offenses; however, it cannot serve as the sole evidence of a taxpayer's violation of tax legislation. Alongside the data collected from the software complex, tax authorities also gather and analyze other evidence indicating the commission of tax offenses. The conducted research shows that there is no normative regulation regarding the use of software complexes in the VAT payment control by tax authorities, which may lead to violations of the rights and legal interests of taxpayers. To address this issue, it is proposed to establish basic principles of using software complexes and responsibility of tax authorities to prove established during using of software complexes facts within the framework of tax control over VAT payment.
Taxes and taxation. 2025;(4):46-56
46-56
Tax Constitutionalism in the Context of the Transformation of the Paradigm of Constitutionalism: Contradictions, Trends, and Prospects for Institutionalization at National and Supranational Levels
Аннотация
One of the least studied yet simultaneously key aspects of the constitutionalism transformation is the phenomenon of tax constitutionalism. In the context of growing fiscal pressure, asymmetry of tax regimes, and the increasing supranational influence on tax policy, the question of the limits of permissible state intervention in citizens' economic freedom from the perspective of the constitution becomes more acute. Historically formed as a form of expression of the social contract and legitimization of public authority through taxation, tax constitutionalism acquires new significance in the era of the crisis of representative democracy and the rise of executive discretion. The subject of this research is the constitutional and legal foundations, law enforcement practices, and prospects for the institutionalization of tax constitutionalism in the context of the transformation of foundational principles of modern constitutional order. The methodological basis of the study is a systemic approach, which implies considering tax constitutionalism as a complex legal institution located at the intersection of public and constitutional law. Comparative legal, axiological, and institutional methods of analysis are applied to identify the evolution of norms and mechanisms of tax legitimization in various jurisdictions. The scientific novelty of the research consists in substantiating tax constitutionalism as an independent concept reflecting the adaptation of constitutional order principles to new challenges of public governance. The article makes the first attempt to systematize the characteristics and models of tax constitutionalism, taking into account the differences between national and supranational fiscal systems. The author shows that modern tax constitutionalism implies not only compliance with formal procedures but also the realization of values of justice, proportionality, and fiscal sustainability. The necessity of constitutional oversight over fiscal innovations, including digital taxes, climate fees, and platform taxation regimes, is substantiated. It concludes that the further development of tax constitutionalism is only possible under conditions of institutional consolidation of mechanisms for public participation and legal transparency. Overcoming existing contradictions requires the development of balanced models of fiscal sovereignty that are compatible with the principles of constitutional identity. The research aims to develop the theory of adaptive constitutionalism as a foundation for a sustainable tax order in the 21st century.
Taxes and taxation. 2025;(4):57-78
57-78
Prospects for the Development of Public Tax Control in the Russian Federation
Аннотация
This article is devoted to the public-legal analysis of the prospects for the development of public tax control in the Russian Federation. The study substantiates the position that public tax control is a crucial type of public control, as the efficiency and effectiveness of tax authorities directly influence the funding of state and municipal budgets and public off-budget funds in the context of continuously increasing budget expenditures. Public tax control is intended to ensure the optimal operation of the aforementioned public authorities. However, the development of the public tax control institution in Russia is associated with several problems: a) the institution of public control is not formalized in the Constitution and the Tax Code; b) the concept of public tax control is not established in legislation; c) there is no unified opinion in scientific and educational literature regarding the content and limits of this type of public control; d) the range of objects and subjects of public tax control requires clarification; e) subjects of public control have an insufficient number of powers. The article employs a number of scientific methods, including formal-logical, comparative-legal, historical-legal, statistical, and sociological methods. To address the identified problems, the study develops and substantiates a system of measures, including, in particular: a) institutionalizing public control in the country's Constitution, and the concept of public tax control in the Tax Code of the Russian Federation; b) developing and adopting a Federal Law “On Public Tax Control in the Russian Federation,” which would establish concepts, principles, objectives, tasks, forms, methods, and special types of activities of this type of public control, clarifying its objects and subjects; c) creating specialized subjects of public tax control, the formation mechanism of which would ensure their independence, objectivity, and impartiality in their work (free from the influence of the objects of public control); d) granting these subjects a system of real powers; e) integrating modern digital technologies for processing large data sets into the practice of public tax control subjects, which would enable the implementation of a significant number of public control activities in real time.
Taxes and taxation. 2025;(4):79-89
79-89