Актуальные проблемы налогообложения физических лиц

The full-scale military aggression against Ukraine led to a massive disruption of value chains, a reduction of jobs, rising unemployment and labor emigration. Legislative initiatives to counteract the socio-economic consequences of the war are insufficiently effective. The purpose of the article is to evaluate the changes in labor and tax legislation during the martial law and to determine the prospects for its improvement. It was found that changes in labor legislation in Ukraine are based on the ideology of neoliberalism, mainly reflect the interests of employers and significantly limit the rights of employees. This increases the risks of the destruction of established institutions of social and labor relations, the losses from which, by analogy with the Syrian conflict, may exceed the losses from the destruction of physical capital. Directions for improving the legislation are proposed, special attention is paid to the rules on the suspension of the employment contract. It is emphasized the need to find a new format of interaction between the state and institutions of the labor sphere, appropriate adaptation of social and labor relations, using the possibilities of digitalization. The impact of changes in tax legislation on employment is analyzed. It was established that the policy of supporting the economy, the key instrument of which is tax benefits, does not sufficiently contribute to the preservation of employment. Based on the study of the international experience of combating economic shocks, a vision of a policy to support the economy is proposed, which should combine measures to preserve jobs, benefits for subjects of economic activity, and liquidity support. The international experience of implementing job preservation schemes, which in EU countries have become one of the main tools for business support during the COVID-19 pandemic, is considered. Conclusions about the relevance of researching the possibilities of their use in Ukraine with the involvement of EU funds were made. Appropriate proposals for authorities have been formulated.

The purpose of the article is to study the historical and theoretical foundations of levying the tax on immovable property other than a land plot, to develop proposals for eliminating gaps in legislation and to expand the scientific basis for studying the above tax. Methodology. The study is based on the analysis of tax legislation in the field of levying tax on immovable property other than a land plot. The article outlines the historical stages of formation and development of taxation of immovable property other than a land plot. This paper analyses the current changes in legislation and establishes that the adjustments to legal regulation have affected the provisions of the list of objects and tax rates, the tax period, and the mechanism of forming a tax decision-notification. It is found that the formation of a scientific basis for the study of taxation other than land is relevant. Recent research in the field of real estate taxation is reviewed and analysed. The main doctrines and scientific positions are presented, and the analysis of domestic legislation is carried out. The imperfection of tax legislation is substantiated. The authors analyse the conceptual framework of the Tax Code of Ukraine. It is also determined that the term "tax collection" is an independent and highly specialised term, which means a set of actions of controlling authorities in the field of tax collection on real estate other than a land plot. A detailed analysis of real estate objects that are not subject to the tax under study was carried out. The research reveals abuses by taxpayers in determining the tax base for real estate objects for which the ownership is not registered. It is proposed to amend the list of taxable real estate owned by spouses in joint ownership. Positive changes in tax legislation under martial law are outlined. The difficulty of effective collection of tax on immovable property other than a land plot is substantiated. Results. In the course of the study of the theoretical foundations of taxation of immovable property other than a land plot, the authors concludes that the legislative framework for taxation has gone through its historical path and continues to evolve. Over the period of validity of the TC of Ukraine, Article 266 has undergone numerous changes, both positive and negative, however, this indicates that the legislator is looking for the best ways to ensure the quality of the tax under study. The article reveals discrepancies in the categorical apparatus of the Tax Code of Ukraine, the legislator uses the terms "administration" and "collection". This paper considers it appropriate to use the concept of levying tax on real property other than a land plot. The authors substantiate the imperfection of legal provisions regulating the collection of tax other than land, which contributes to the abuse of taxpayers. A positive novelty of the legislation is the inclusion of those objects that are not subject to taxation that are destroyed, damaged (requiring major repairs) and destroyed during the period of hostilities. Practical implications. The article provides proposals according to which amendments to the TC of Ukraine will facilitate more efficient collection of tax on immovable property other than land plots. Value/originality. The article provides proposals for amendments to the TC of Ukraine in terms of taxpayers' obligations, clarification of the preferential category of the tax base and jointly owned property.

The tax reform of 2025 has become one of the largest changes in recent decades. The groundbreaking changes in tax legislation adopted as part of the tax reform raise many questions among representatives of small and medium-sized businesses. This explains the relevance of the research topic. The purpose of the study is to analyze the most important changes introduced in business taxation in connection with the announced tax reform. The objectives of the study are to identify both the positive and negative sides of the tax reform based on the study of changes in tax legislation, including issues of taxation of small businesses in connection with applying the simplified taxation system, and to assess the degree of their impact on the budgets of the budgetary system of the Russian Federation. Materials and methods. The information base of the study was data from reports of the Federal Tax Service of the Russian Federation on the accrual and receipt of taxes and fees to the budgets of the country's budgetary system, reports on the tax base and the structure of tax accruals for which changes are envisaged, and federal laws that amended the Tax Code of the Russian Federation. The study was conducted using research methods generally accepted in economics: analysis and synthesis, generalization, comparison, etc. Results. The main directions of tax reform – 2025 are examined. A comparative assessment of tax revenues in 2020 and 2023 is made. The following trends were identified: tax changes are aimed at increasing the tax burden on taxpayers and budget revenues of the budgetary system of the Russian Federation, primarily the federal budget. Conclusions. Tax changes are mainly of a fiscal nature, and the tax burden will increase not only on businesses, but also on individuals (both directly with the introduction of a progressive scale of personal income tax, and indirectly through an increase in the tax burden on businesses and subsequent transfer to end users), which will eventually result in an increase in budget receipts. Due to the tax reform, the burden on businesses will increase, budget revenues will increase, but the situation of regional and local budgets will not improve.

The article deals with the cost of tax compliance which arises for taxpayers from tax complexity and the constant changes in tax legislation. A socially responsible institution for the fiscal aggression is the Financial Administration of the Republic of Slovenia, as its powers and responsibilities creates the tax position of individuals, businesses and the entire economy. The aim of our research is to encourage socially responsible behaviour of legislation institutions in adopting the tax legislation, which will help to improve the social responsibility of taxpayers and increase tax compliance.

Introduction. Tax audits are a crucial part of any country’s financial system, ensuring taxpayers comply with the law and pay their taxes on time. However, conducting tax audits during wartime can be complicated due to various factors. Ukraine, currently experiencing an extremely difficult period in its development due to the constant threat of war and geopolitical conflicts, serves as the context for this study. The purpose of the paper is to explore the unique challenges of conducting tax audits during wartime. It seeks to understand the changes in tax legislation and audit procedures during war, the increase in tax violations and abuses, and the challenges faced by fiscal authorities in ensuring tax compliance and maintaining budget stability. Results. The study reveals several key features of conducting tax audits during wartime, including changes in legislation, increased tax violations, challenges for fiscal authorities, and preparation for audits. Based on these findings, practical recommendations have been developed for businesses and taxpayers on preparing for tax audits during military operations. Conclusion. The paper concludes with the need for legislative adaptation, the use of technology to simplify the audit process, promoting transparency and mutual trust between tax authorities and taxpayers, and strengthening control over compliance with tax legislation. Despite the challenges that may arise during a state of war, compliance with tax legislation remains the obligation of every taxpayer.

In todayâ??s economic climate, floating production, storage and off-loading systems (FPSOs) are widespread in the offshore industry and have proven to be an effective solution in the development of Marginal Fields. There are currently 81 FPSOs and 83 FSOs in operation worldwide. In the past 5 years 72 floating production units have been installed and in the next five years there is a forecast of a further 116 floaters being considered. (6) The Bijupira and Salema program included delivery of all systems (excluding wells) under an EPCI Contract combined with a separate Contract to operate the facilities for a period of 13 years. The project involved engineering and coordinating all the equipment and work processes from the Christmas Tree Wing Valve to the Offloading Hose connecting to the shuttle tanker. In addition, the work involved the completion of the engineering, the fabrication and installation of the subsea and surface components, the FPSO conversion and topside preparation for the installation of the production and utility modules. This included the pre-commissioning, start up and commencement of the project operational phase. This ambitious program was achieved by closely coordinating the management team and with the cooperation of the principal contracting parties. There is little doubt that the role of the client (Enterprise Shell) and the relationship with MODEC as lead contractor was a key factor in the projectâ??s success, leading to the achievement of both an aggressive schedule, low cost and an exemplary project safety record. Of importance is that the above was achieved against a background of both a major corporate acquisition, with Shell acquiring Enterprise Oil in May 2002 and a change in tax legislation in Brazil. Both these events caused major changes in project execution strategy and had to be very carefully managed to negate the impacts on cost and schedule. In the case of the acquisition significant effort was put into ensuring strategic (re) alignment between all parties and in the case of the changes in tax legislation it was required to revise the execution strategy and sail incomplete from the shipyard and complete work in the more complicated and less favourable environment offshore in Brazil. Within a period of 27 months from the execution of the LOI to the MODEC/FMC organization, the offshore development was producing And the production is being steadily ramped up towards the contract rate of 70,000 BOPD with nearly all systems fully commissioned and started up. Finally, the paper discusses experience gained by MODEC and Shell during the project execution phases with particular focus on those areas considered to be critical in the execution of a low cost development. Results to date have confirmed that, although providing an economically attractive solution, the execution strategy could have been further improved resulting in potential additional cost savings and improved start up performance. Note: The name "Fluminense" is a Portuguese word meaning "belonging to the State of Rio de Janeiro".

The 1984 UK Finance Act introduced changes in tax legislation with consequences for both capital and revenue expenditure on plant. The one- and two-cycle rent models for capital equipment replacement and the infinite-cycle discounted-cost model are extended here to incorporate the new tax features. A specific replacement problem is used as the basis of an analyis of the sensitivity of the optimal replacement period to parameters. Whilst all these models are consistently insensitive to the new tax legislation, there is no consistency across models with respect to which parameters dominate choice of optimal replacement period.

This article deals with the problem of assessing the limits of public economic interest in civil legal relations. Analyzes changes in tax legislation and the limits of their "penetration" through public economic interest in Civil Law. A number of author's criteria for evaluating such limits in civil relations are proposed. The solution of the problem under study will allow: first, to determine the limits of the legal influence of public economic interest in contractual legal relations; second, to increase the effectiveness of the Institute for the protection of the rights of business entities in tax legal relations.

The paper discusses how the war affects decentralization processes in Ukraine including changes in fiscal responsibilities and distribution of power. The discussion is based on the thesis that decentralization increases local resilience and plays a crucial role in the future recovery. However, the conducted analysis supports the idea that more decentralisation is not necessarily connected to better economic outcomes. Improving local governments’ performance is a crucial point for future decentralization in Ukraine. Despite the recognition of Ukrainian decentralization reform as one of the most successful and advanced in terms of its implementation even before the full-scale invasion, there were still a number of unresolved issues hampering the development of capable communities (hromadas), including low managerial capacities of local authorities, and lack of understanding of the management system at the local level. The full-scale russian invasion brough new challenges and put a lot of Ukrainian local communities under severe pressure to make immediate decisions. However, according to expert opinions, the decentralization was one of the main factors of survival of many Ukrainian local communities during the first days and weeks of the invasion as local authorities already had an experience of making independent decisions without getting a ‘call from Kyiv’. Recently local communities in Ukraine lost a significant part of their financial resources due to the changes in tax legislation and got a significant task to ensure recovery and rebuilding which is an extraordinary challenge in the current situation.

The paper highlights the legal basis for the activities of agricultural enterprises in line with changes in tax legislation. It is pointed out that the dynamics of legal norms results in the imperfection of the legal regulation of taxation of agricultural enterprises, while the harmonization of Ukrainian legislation with the law of the European Union is a necessary condition for our country's accession to the European community. Thus, as a result of the administrative reform and decentralization processes in Ukraine, communities function as the main foundations of the activities of collectives of settlements, Starostyn districts. We have established that an agricultural enterprise in modern communities is an enterprise whose main activity is the supply of agricultural goods (services) produced (provided) by it on its own or leased fixed assets, as well as on toll terms, in which the share of agricultural goods/services is not less than 75 percent of the value of all goods/services delivered during the previous 12 consecutive reporting tax periods combined. In the case of creation of a new agricultural enterprise, which operates for at least 12 months, the specified share is determined for each individual reporting tax period. In addition, this does not include taxable transactions for the supply of fixed assets that were part of its fixed assets for at least 12 consecutive reporting tax periods in total, if such transactions were not permanent and did not constitute a separate business activity. Such enterprises have the right to choose a general or simplified system of taxation. Prospective directions of further improvement of the national legislation are offered taking into account necessity of understanding of features of realization of agricultural activity, a disparity of the prices for production and means of its manufacture, dependence on natural and climatic conditions, profitability of separate branches of agriculture, prevention of discrimination between agricultural commodity producers for the taxation of small agricultural producers.

Changes in tax legislation on regional taxes in 2022.

In martial law conditions, one of the tasks of the state is to minimize the recession and restore the level of entrepreneurial activity of business entities through tax regulation tools. The article aims to reveal the peculiarities of taxation and tax restrictions, as well as to determine their combined impact on the entrepreneurial activity of taxpayers of the single tax of the third group under martial law. Scientific approaches to revealing the essence of entrepreneurial activity were summarized. The Global Report 2021/2022 “Opportunity Amid Disruption” results by the global research program on entrepreneurial activity were elaborated. The increased possibilities of entrepreneurial activity in martial law conditions were emphasized. The author's concept of “entrepreneurial activity” was substantiated. The terminological origin and essence of the term “peculiarities of taxation” were revealed. The concept of “peculiarities of taxation” was introduced into terminological circulation. The need to refer to the term “peculiarities of taxation” to the group of additional elements of the tax has been proven. Three types of tax restrictions were distinguished according to the classification feature “by groups of single taxpayers’. An analysis of changes in tax legislation regarding the removal of tax restrictions for payers of the single tax of the third group under martial law was carried out. Differences in using tax restrictions in peacetime and during martial law were shown. It was revealed that removing tax restrictions on the income and the number of employees for taxpayers of the third group of single tax was timely and appropriate. It was proposed to spread the experience gained in removing tax restrictions for taxpayers of the single tax for the post-war period. Changes in the structure of third-group single taxpayers in the Khmelnytskyi region were analyzed. A deviation in the registration number among entrepreneurs and legal entities of the mixed group of taxpayers of the third group of single tax was revealed. The conceptual direction of regulation of tax restrictions in Ukraine was substantiated.

In order to determine what major developments have taken place in tax law in Israel over the last 40 years, it is first necessary to formulate criteria with which to estimate the importance or centrality of changes in tax legislation. The emphasis here is on legal developments (in legislation and case law) rather than on changes in the tax system and tax policy. In the field of taxation, legal, economic and social questions are, however, interlinked; and it is moreover, a legal tool — legislation — that determines the tax system and its composition of various tax bases.

The article considers the mechanism of tax consultancy as an important element of the management of the tax component of the economic security of an enterprise, which is particularly relevant in the context of constant changes in tax legislation and growing requirements for transparency of financial statements. Tax consultancy is a complex process of providing companies with qualified assistance in the field of tax planning, optimisation of tax liabilities and management of tax risks. It is substantiated that tax consulting not only helps to reduce the tax burden, but also ensures compliance of the company's tax policy with the requirements of current legislation, which, in turn, is a guarantee of long-term stability and financial sustainability of the company. The article examines the structural elements of the tax liability management mechanism, which include tax planning, ensuring conditions for timely and correct calculation of tax liabilities, as well as organisational and control components. Particular attention is paid to the analysis of the tax planning process as one of the key stages of tax consulting. It is determined that effective tax planning allows an enterprise to optimise the structure of income and expenses, thereby reducing the tax burden and ensuring the rational use of financial resources. This paper considers the methods of ensuring compliance with tax reporting requirements as an important factor in the process of tax consulting. The function of tax consultancy in the formulation and execution of strategies designed to mitigate tax risks and enhance the efficacy of enterprise financial management is established. The necessity of utilising contemporary information technologies in the domain of tax consulting is underscored, as this enables the enhancement of the precision and efficacy of managerial resolutions pertaining to taxation. It can be concluded that effective tax consulting plays a pivotal role in enhancing the economic resilience of an enterprise. It serves to fortify the enterprise against external and internal threats, including those posed by shifts in the tax environment and economic challenges.

Within the framework of the study, an analysis is conducted of the strategic function of tax planning as a factor for maintaining sustainability and expanding small and medium-sized enterprises in the context of the economic turbulence of 2024–2025. The argumentation is structured around the author’s methodology Tax as Strategy, within which fiscal architecture is interpreted not as an inert external constraint, but as a controllable contour of capital optimization and a mechanism for reducing agency costs. The conceptual core of the work is formed by propositions concerning the transformation of business organization: from the dominance of survival heuristics at the stage of stabilization to institutionally embedded and procedurally formalized structures at the stage of scaling. Substantial attention is devoted to startups and entrepreneurship in the United States, where financial formalization acquires the significance of a highly informative signal for external stakeholders and functions as a condition of trust on the part of counterparties, investors, and the regulatory environment. The study synthesizes empirical evidence regarding the effectiveness of transitioning to the S-Corporation model, which is associated with tax savings in the range of 15–35% and an increase in net profit of 20–40%. A separate analytical block examines the impact of artificial intelligence and digital platforms on fiscal resilience, and also constructs a prognostic model of adaptation to probable changes in tax legislation after 2025. The methodological framework is grounded in the theory of dynamic capabilities, agency theory, and contemporary approaches to risk management that are relevant to an environment of high inflation and market volatility. Thus, tax planning is revealed as an element of strategic management that is capable of simultaneously enhancing organizational viability, supporting growth, and ensuring the alignment of interests among key participants in the economic process.