Abstract: The article is devoted to the study of the content and correlation of the concepts of "digital currency" and "stablecoin". The subject of the article is the peculiarities of the legal regime of digital currencies and stablecoins, as well as the tax consequences of transactions with such assets. The purpose of the study is to determine the potential tax consequences of transactions involving digital currency and stablecoin, taking into account the economic and legal relationship of these concepts. As a result of the research conducted by the author, it is concluded that under Russian law, the main distinguishing feature of a stablecoin from a digital currency will be the presence or absence of a certain obligor. It is noted that despite the absence of a legally defined term "stablecoin", some of its types can be qualified as digital currencies or digital rights. In the case of a possible qualification of a stablecoin as a digital right, such a stablecoin can be characterised as a digital right that includes a monetary claim or as a hybrid digital asset. The fact that the value of a stablecoin is tied to a specific value does not in itself affect the characterisation of such an asset for the purposes of considering potential tax consequences. The lack of legally established rules for the taxation of digital currencies affects the ability to determine the potential tax consequences of transactions involving a stablecoin, if it is classified as a digital currency. It is concluded that the existing explanations of the state authorities on the taxation of digital currencies are not sufficient to correctly determine the tax consequences of transactions with such assets. The results of the study can be used in the development of legislation on the taxation of transactions with digital currencies and stablecoins.

Keywords: corporate income tax, digital financial assets, mining, taxation of stablecoins, digital assets, digital currency taxation, cryptoassets, stablecoin, cryptocurrency, digital currency

Abstract: The subject of this study is the administration of universal excise taxes, specifically one of its forms—value-added tax (VAT) – in the countries of the Eurasian Economic Union (EAEU). The study examines VAT within the context of tax system harmonization, digitalization of administration, and taxation of cross-border transactions. The focus is on differences in VAT rates, levels of process automation, and approaches to tax administration, which create barriers to integration and reduce the efficiency of tax systems. Special attention is given to the impact of digitalization on improving VAT collection, reducing the tax gap, and increasing the transparency of tax accounting. Additionally, the study explores the experiences of international integration organizations, such as the European Union, in tax unification and the implementation of digital platforms for taxpayer accounting and the administration of cross-border transactions. The methodological basis of the study includes the analysis of statistical data on VAT receipts, a comparative analysis of the tax systems of EAEU countries, and an examination of international experience, particularly the practices of the European Union. Methods such as generalization, modeling, and economic and mathematical analysis were applied to assess the effectiveness of current and prospective VAT administration mechanisms. The results demonstrate a strong dependence of tax revenue growth on the level of digitalization in administrative systems. It has been established that creating a unified digital VAT accounting platform can minimize the tax gap, improve tax collection, and reduce administrative costs. Key barriers to harmonization have been identified, including differences in VAT rates and the absence of a unified approach to the taxation of digital services. The practical significance of the results lies in their potential application to the development of joint programs among EAEU member states in the field of tax policy coordination, as well as the creation of a common supranational tax policy for the EAEU. Recommendations have been developed to adapt international best practices, including the introduction of automated taxpayer accounting systems, and specific steps have been proposed to unify the taxation of cross-border trade. The article concludes by emphasizing the need for coordinated efforts among EAEU countries to create a unified tax strategy. Such a strategy would enhance VAT collection, strengthen economic integration, and foster more transparent interactions between market participants.

Keywords: Tax Accounting Automation, Tax Gap, Economic Integration, Cross-Border Transactions, VAT Administration, Tax Digitalization, Tax System Harmonization, Eurasian Economic Union, Value-added tax, Universal excise

Abstract: In the era of digital transformation, artificial intelligence (hereinafter – AI) is becoming a key tool in tax administration. This article is a study of the possibilities of using AI in the tax administration of insolvent organizations (bankrupt), as well as the mechanics of introducing AI technologies into the work of structural divisions of tax authorities responsible for ensuring bankruptcy procedures for insolvent organizations and the prospects for their adaptation in the Russian tax administration system. Currently, bankruptcy is a macroeconomic factor and the need to apply AI in Russian practice, including to ensure bankruptcy procedures, is possible through the introduction of algorithms for monitoring and analyzing financial statements of enterprises. The article analyzes the international experience of using AI in the work of judicial and fiscal authorities, in order to adapt the selected approaches within the Russian system, which will contribute to increasing transparency and efficiency of tax administration. The basis of the research methodology is formed on the basis of general scientific and special research methods, including methods of comparative analysis, a method of generalizing results when formulating conclusions and presenting priority areas, a method of system analysis and expert assessment. The novelty of this study lies in the adaptation of tools and the introduction of AI mechanics into the tax administration of insolvent organizations (bankrupt). Conclusion. The introduction of AI into the work of the Federal Tax Service of Russia, in terms of tax administration of insolvent organizations, is a major vector towards improving the effectiveness of bankruptcy procedures for insolvent organizations. At the same time, the development of the institute of bankruptcy with the gradual introduction of AI contributes to: the development of predictive analytics, the construction of models for predicting the outcome of cases, the identification of distortions in the debtor's statements and balance sheet, reducing the cost of administering bankruptcy procedures, reducing the time spent on data processing. International experience demonstrates the high effectiveness of such technologies. The adaptation of the analyzed tools for Russian practice will open up new opportunities for digitalization, increase the transparency of tax administration, and also contribute to the development of international interdepartmental electronic interaction.

Keywords: bankruptcy estate, data analysis, creditors, deferred taxes, tax administration, debtor, arbitration manager, artificial intelligence, insolvency, institute of bankruptcy

Abstract: In the context of a complex geopolitical situation, an urgent issue is to ensure growth of the budget revenue to finance significant national projects, including the new national project "Family". The purpose of the study was to analyze the possibility of introducing a new tax, namely, a special tax to finance government support measures for families with children. The following tasks were defined: to analyze the current demographic situation in Russia, to conduct a historical analysis of the practice of levying a tax on childlessness and its effectiveness, to develop a new special tax in modern conditions. The study of the subject area revealed the futility of using the tax on bachelors and childless as a tool for increasing the birth rate. The work is based on the analysis of official data from Rosstat for the period from the 1950s to the present. Based on extrapolation and the averaging method, an estimate is given of the amount of revenue from the proposed tax to the budget. Based on the theoretical analysis of the economic essence of the tax, as well as the understanding of fair taxation, the possibility of introducing a new tax as a tool for additional redistribution of income between individuals with and without dependent children has been proven. The result was the development of conceptual parameters of a "special tax to finance measures of state support for families with children". The methodology for constructing a special tax is based on the fact that its size should be determined depending on the share of the subsistence minimum for a child to the average wage. The practical significance of the study lies in the possibility of practical implementation of the tax, taking into account the justification of all its mandatory elements.

Keywords: large families, minimum cost of living, tax fairness, income tax, tax on small families, bachelor tax, demographic hole, tax regulation of birth rate, taxes, social taxation

Abstract: The object of the study is the pension system of the Russian Federation, the subject is the implementation of the Strategy for the Long–term Development of the Pension System of the Russian Federation until 2030 ("Strategies"). The purpose of the study is to propose fiscal measures to ensure the achievement of the goals and objectives of the Strategy. The article considers the achievement of targets for the replacement rate and the size of the insurance pension, assesses the degree of development of the three-tier pension system, its balance and financial stability, the amount of budget revenues of the budgetary system of the Russian Federation from the taxation of pensions for non-state pension provision. Special attention is paid to the dynamics of the parameters of insurance premiums, the indicators of the budget of the Social Fund of Russia and its shortfall in income due to the effect of preferences for the payment of insurance premiums. The paper identifies the factors influencing the possibility of fully implementing the objectives of the Strategy and achieving its top-level goals by 2030. The work uses coefficient, graphical, factorial, comparative, vertical and horizontal analysis of pension provision indicators and budgets of the budgetary system of the Russian Federation, which determine the problems of Strategy implementation and ways to solve them. It is concluded that the target value of the replacement coefficient and the amount of the insurance pension are currently not being reached, both at retirement and at the beginning of the formation of pension rights in 2024, and the provisions of the Strategy regarding preferences for insurance premiums are not fully respected. The expenses of the SFR budget for the payment of insurance pensions are not fully covered by insurance premiums for compulsory pension insurance, however, a faster increase in the marginal base for insurance premiums and average wages than the fixed payment amount and the cost of the individual pension coefficient, as well as medium-term demographic trends and continued increase in the retirement age, will contribute to ensuring financial stability and balance the Russian pension system. The parameters affecting the level of pension provision in the distributive part of the OPS have been determined. The author proposes fiscal measures aimed at achieving the objectives of the Strategy, and evaluates their effects on revenues and expenditures of the budgets of the budgetary system of the Russian Federation.

Keywords: tax expenses, tax benefits, insurance contribution rates, insurance contributions, replacement rate, mandatory pension insurance, pension provision, pension system, rate policy, insurance pensions

Abstract: The object of the study is the legal relations between interdependent persons in relation to the fulfillment of their tax obligations. The subject of the study is the tax legislation of the Russian Federation, judicial arbitration practice in tax disputes, and the doctrinal views of modern jurists. Special attention is paid to the analysis of current law enforcement practice, analyzing which the author tries to find out current trends in the application of tax legislation. The relevance of the chosen topic is due to the need to find an objective balance between public and private interests. On the one hand, businesses strive to minimize their tax costs by generating profits for their beneficiaries. Often, complex schemes are used for this, which are not always logical from the point of view of building civil law relations, but formally do not contradict the legislation. On the other hand, the supervisory authorities, within their powers, analyze the schemes built by entrepreneurs and qualify them based on the need to fulfill the constitutional obligation to pay taxes and the inadmissibility of arbitrary evasion from this obligation. In preparing the work, the author used the following methods of scientific cognition: formal legal, comparative legal, induction, deduction and structural method of legal modeling. The novelty of the undertaken research lies in a consistent and systematic analysis of the current law enforcement in tax disputes involving interdependent persons. The work convincingly shows, using specific examples, that not only commercial, but also non-commercial legal entities strive to optimize their tax obligations. At the same time, it was revealed that the tools for such optimization are quite wide: splitting up a business, transferring employees from one organization to another, using the same official website for the current activities of several legal entities with almost identical founders. Sometimes it is practiced to conclude civil law transactions with similar conditions for consumers, but with a variety of persons on the supplier's side. At the same time, the financial and economic activities of various taxpayers are controlled by the same individuals (this includes, among other things, signing bank documents and tax reports).

Keywords: transactions, tax optimization, law enforcement, judicial practice, legal entities, tax legislation, taxation, taxes, interdependent persons, legality

Abstract: The article is devoted to the issue of calculating valid tax liabilities in the process of tax control in the Russian Federation. The relevance of the topic is due to the lack of a unified methodology for calculating valid tax liabilities (VTL), which leads to a significant number of tax disputes, inconsistency between the position of official financial authorities and judicial practice, violation of the rights and economic interests of taxpayers, lack of uniformity in the approaches of tax and law enforcement agencies in the process of determining the amount of valid tax liabilities within the framework of tax control, and law enforcement activities. The object of the study is the social and economic relations that develop between taxpayers and tax authorities in the process of tax control. The subject of the study is the process of determining the amount of valid tax liabilities when identifying tax offenses. The research used general scientific methods of cognition – analysis, synthesis, induction, description, principles of formal logic, as well as private scientific methods - graphical, method of analyzing specific legal situations. The study was based on the analysis of scientific publications on relevant topics, as well as on the analysis of judicial practice in tax disputes. Within the framework of the article, recommendations are given on the formation of a unified methodology for calculating the VTL on the example of one of the directions for obtaining unjustified tax benefits – the illegal use of tax incentives and reduced tax rates. Within the framework of the study, the application of the actual calculation method for this type of tax offenses is justified; the risk markers of the scheme are identified and options for measures implemented by the tax authority to establish valid tax obligations are proposed; the accounting procedure for corporate income tax expenses and value added tax amounts, taking into account tax deductions, is determined. The novelty lies in the formation of a methodology for calculating the VTL in relation to the unjustified application of tax benefits and reduced rates, which can and should be an integral part of a single methodology that takes into account the main directions of obtaining unjustified tax benefits. The practical significance lies in the possibility of using such a methodology by both taxpayers and tax authorities based on the results of tax control measures, which will reduce the volume of contradictions, protect both the interests of the budget and the economic interests of taxpayers at the same time.

Keywords: risk markers of tax schemes, unjustified tax benefit, additional taxes, tax disputes, tax rates, tax benefits, The method of calculation of the VTL, technical companies, valid tax liabilities, tax migration

Abstract: This article is devoted to the analysis of the need and possibility of creating public councils at the tax inspections of the Federal Tax Service of Russia (hereinafter also referred to as the Federal Tax Service of Russia) at the grassroots level (in particular, for district, urban, inter–district inspections). The current legislation on public control, in particular, Federal Law No. 212-FZ dated July 21, 2014 "On the Basics of Public Control in the Russian Federation" provided for the possibility of creating public councils under federal executive authorities. Today, such councils exist under the Federal Tax Service of Russia and its territorial divisions in the Russian regions. The authors substantiate the insufficiency of this category of subjects of public control under the Federal Tax Service of Russia and territorial divisions at the regional level, since a significant part of on-site and desk inspections of taxpayers in the country are carried out by low-level inspections. The article uses a number of scientific research methods, in particular: formal-logical; historical-legal; comparative-legal; statistical; sociological; method of analyzing specific legal situations. The paper formalizes and analyzes the main problems that complicate the processes of formation and creation of public councils under the inspections of the Federal Tax Service of Russia at the grassroots level, among which are: the absence in the legislation on public control of a direct indication of the possibility of creating public councils under the territorial divisions of federal executive authorities; the controversial nature of the mechanism for the formation of public councils under the Federal Tax Service of Russia and its territorial divisions; lack of consolidation in tax legislation and local acts of the Federal Tax Service of the need and possibility of creating such public councils at the inspectorate of the Federal Tax Service of Russia at the grassroots level; lack of elaboration in the scientific legal doctrine of specific forms, methods and types of public control measures for these subjects; their weak powers; weak use of modern digital technologies; the dependence of these entities on the Federal Tax Service of Russia in terms of material, technical, property, and organizational base. The article develops a system of measures to resolve these problems.

Keywords: prevention, tax audits, tax inspections, Federal Tax Service, Russian Federation, democracy, public control, warning, corruption, crimes