Registration Number
0126U001055,
R & D request
Title
Fulfillment of the Tax Obligation in the Context of Permanent Transformation of Tax Administration: Issues of Regulatory Framework and Law Enforcement Practice.
Head
Dmytro A. Kobylnik, Доктор юридичних наук
Serhii V. Broiakov, Доктор філософії
Registration Date
30-01-2026
Organization
Yaroslav Mudryi National law university
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The period is driven by Ukraine’s entry into a new stage of tax transformation, defined by the National Revenue Strategy until 2030, as well as by its commitments to the EU under the Association Agreement and the need to modernize tax legislation in line with the latest standards of tax and legal regulation. Global trends (OECD Pillar 2, the Crypto-Asset Reporting Framework (CARF), etc.) will require Ukraine to undertake a radical renewal of its regulatory framework in the coming years. The research combines both norm-setting and law-enforcement components, making it well-suited for a comprehensive and in-depth examination of current issues in the field of taxation. The scientific novelty of the research for 2026–2030 will consist in a comprehensive analysis of the latest institutions of tax law, in particular transfer pricing (TP), controlled foreign companies (CFCs), and the automatic exchange of tax information (CRS and FATCA). Special attention will also be given to the study of relevant case law concerning disputes related to TP and withholding taxation on passive income paid to non-residents (dividends, interest, royalties). For the first time in Ukrainian tax-law doctrine, the following will be examined systematically: problematic aspects of the CFC regime and possible solutions; the balance between public and private interests under special tax-law regulations during martial law; issues related to the stability of tax legislation and case law concerning fundamental matters of tax-legal regulation; and the adaptation of the national tax system to modern international standards. Practical significance: The results may be used for reforming the institutions of the Tax Code of Ukraine, improving tax administration mechanisms, and optimizing tax control procedures. The research will be essential for studying the implementation of modern tax-administration institutions, including TP, CFCs, and the automatic exchange of tax information (CRS and FATCA), among others
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2026-01-30
