DIGITALIZATION IN THE DEVELOPMENT OF TAX CONTROL AND MONITORING: CONTEMPORARY TRENDS

Abstract

Introduction. This article examines current trends in the transformation of tax control and monitoring under the influence of digitalization. The digital transformation of tax administration, enshrined in the Development Strategy of the Federal Tax Service of Russia until 2030, requires a rethinking of legal control mechanisms. Traditional forms of control (on-site and desk audits) are being supplemented by automated systems, which in turn give rise to new legal frameworks such as tax monitoring, the automated VAT system (ASK VAT-2), and product traceability. The purpose of this study is to identify and analyze legal trends in the digitalization of tax control based on the provisions of the Tax Code of the Russian Federation (hereinafter, the Tax Code), as well as to identify legal risks and regulatory gaps. The author draws conclusions regarding the development of a proactive control and monitoring model and identifies challenges and prospects for the further development of digital tax administration in the Russian Federation. The article also analyzes changes in the methodology of the Federal Tax Service (hereinafter, the FTS) of Russia's control function related to the implementation of artificial intelligence technologies, big data analysis, and the transition to comprehensive digital oversight. Methods. The study is based on formal legal and comparative legal methods. To identify common approaches and key differences in the organization of tax monitoring, as well as methods for normalizing performance indicators, we used methods of systematizing legal norms, critically analyzing law enforcement practices, and synthesizing the findings related to account blocking, document retrieval in the digital environment, and the application of a risk-based approach. Results. The following legal trends were identified: expanding grounds for automatic account blocking; evolving approaches to proving unjustified tax benefits using digital traces; legal uncertainty regarding the status of automated decisions made without inspector involvement and the admissibility of their appeal. Discussion. The results of the study indicate the development of a case law framework around digital tax control tools. The limits of automatic document retrieval remain debatable. The need to amend Article 10 is substantiated. Articles 76 and 88 of the Tax Code of the Russian Federation, in terms of: a simplified procedure for taxpayers to appeal automated decisions and the introduction of liability for the untimely automatic unblocking of accounts. A conclusion is made regarding the transition to a predictive justice model in the tax sphere, which requires new standards of proof.