Tax Liability in the Context of Digitalization: The Transformation of the Concept

Introduction: the article analyzes the development of the concept of tax liability as it occurs under the influence of the digitalization process. The analysis is based on Russian tax legislation and modern provisions of the tax law doctrine. The fundamental importance of the study is determined by its focus on a comprehensive assessment of the legal regulation of tax liability as one of the central categories of tax law that plays this role in the context of digital transformation. Purpose: based on the approaches to the concept of tax liability that exist in the science of tax law, to analyze its content and indicate the characteristic features inherent in it in the conditions of digitalization of the economy. Methods: methods of analysis and synthesis; the principle of unity of theory and practice; formal legal, historical methods, method of interpretation of law. Results: the essential features of tax liability in the context of digitalization have been formulated; individual problems and directions for improving its legal regulation have been identified. Conclusions: based on the consideration of tax liability as a tax, as one of legal obligations, as the totality of taxpayers’ duties, as well as on the results of an analysis of the institutional affiliation of the norms on tax liability, the following signs (features) can be identified: it is a set of active interactions of various participants in tax relations, the list of which is expanding in the context of digitalization; it is regulated by tax legislation, provided that the role of experimental regulation increases and the trend toward decodification strengthens; it is a system that includes obligations to pay taxes, submit tax reports, and register with tax authorities, which, in turn, are characterized by further differentiation of models of legal regulation of such obligations; it retains a public-law character, which manifests itself in the obligation to fulfill tax obligations implemented in the context of digitalization based on the transition to the model of cooperation of tax authorities with taxpayers; it is fulfilled under the conditions of mandatory use of digital technologies, as a result of which a digital mechanism for fulfilling tax obligations is formed; it is characterized by stage-by-stage development.