LEGAL FOUNDATIONS FOR TНE FORMATION AND DEVELOPMENT OF TAХ COMPLIANCE IN UКRAINE |
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Author |
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In heading |
Law; | ||||
Signed print |
27.11.2025 | Issues number |
2025 - № 4 (63) | Page |
44-62 |
Type of articles |
Scientific article | Code UDK |
347.73 | ISSN print |
2411-5584 |
Abstract |
In the article, the current state, stages of formation, and organisational and legal foundations of the development of tax compliance in Ukraine are examined in the context of the reform of the tax administration system and the implementation of the National Revenue Strategy until 2030. It is demonstrated that the formation of the national model of tax compliance is the result of a gradual transition from the fragmented application of risk management to the creation of a comprehensive tax risk management system in line with international OECD standards and ISO 31000:2018. The article discloses the substance of tax compliance as a holistic set of measures aimed at increasing the level of voluntary fulfilment of tax obligations by taxpayers, minimising tax risks, and reducing the need to apply control and enforcement procedures. A classification of tax risks is carried out according to the content of tax obligations, their probability, and source of origin, and the main response tools of tax authorities depending on the degree of risk are identified. It is substantiated that tax risk management is a cyclical process that includes the identification, analysis, assessment, monitoring, and review of risks, as well as the evaluation of the effectiveness of compliance measures. On the basis of a comprehensive analysis of the normative, organisational and factual preconditions for the establishment of tax compliance in Ukraine, a periodisation of the development of the legal framework for its introduction is proposed. five key stages are distinguished: the pre-institutional stage (until 2018), the assessment and diagnostic stage (2018), the stage of digital modernisation (2018-2020), the pandemic and wartime stage (2020-2023), and the institutional and regulatory stage (from 2023 to the present). It is emphasised that each of these stages is characterised by specific objectives, challenges, and instruments that have significantly influenced the formation of the modern compliance model. The paper argues that the broad implementation of risk-based approaches and the establishment of an effective system of tax compliance are essential conditions for increasing the efficiency of tax administration, reducing the shadow economy, and ensuring transparent and predictable relations between taxpayers and the state. It is further substantiated that, by its legal nature, tax compliance should be normatively consolidated as an element of the information and analytical support of the activities of controlling authorities, which determines the need for appropriate amendments to the Tax Code of Ukraine. | ||||
Keywords |
tax planning, taxpayers' rights, tax obligation, legal relations, public administration, information, compliance, tax risks, offences, public administration. | ||||
Reviewer |
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External reviewer |
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Article in PDF |
Visnik Ekonom teor_4_2025_44-62 | ||||
Bibliography |
Kostenko, У. О. (2025). Pravovi zasady stanovlennia ta rozvytku podatkovoho komplaiensu v Ukraini [Legal Foundations for the Formation and Development of Тaх Compliance in Ukraine]. Ekonomiсhna teoriia ta pravo - Eсonomiс Theory and Law, 4(63), 44-62. DОI: https://doi.org/10.31359/2411-5584-2025-63-4-44 [in Ukrainian]. | ||||
Code DOI |
https://doi.org/1О.31359/2411-5584-2О25-63-4-44 | ||||
This post is also available in: Ukrainian
18.06.2026
