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The subject. Currently, the courts are actively using a new term - "valid tax liability", or "the actual amount of tax liabilities". This term is the result of the activities of judicial authorities, however, judicial practice on determining the actual tax liability for personal income tax is only being formed and is unstable. Therefore, the subject of the study of this article is a comprehensive analysis of law enforcement practice in the field of determining the actual tax liability of individuals for personal income tax.Purpose of the study is to dare to solve the enforcement problems that arise when determining the actual tax liability of individuals for personal income tax.The methodology. The authors uses the formally legal interpretation of Russian legislation, comparative analysis of Russian and European literature as regards the determination of a valid tax liability.The main results, scope of application. The authors analyzed the concept of "valid tax liability", and also studied the problems of determining the actual tax liability in the context of the law enforcement practice of the Supreme Court of the Russian Federation. Based on law enforcement practice, the main problems in determining the actual tax liability are highlighted, to which the authors attribute the incorrect qualification of the object of taxation, the incorrect qualification of the nature of the taxpayer's activity and its status, as well as the incorrect determination of the taxpayer's tax base. The article also touches on the main problems in the reimbursement of the amount of overpaid personal income tax.Conclusions. When determining the taxpayer's actual tax obligation to pay personal income tax, the tax authorities are guided by a "pro-budget" goal, seeking to increase the tax base due to incorrect qualification of the taxable object, the status of the taxpayer, or questioning the nature of its activities, which leads to the formation of arrears and forms the composition of an administrative offense.In an effort to restore their violated rights, an honest taxpayer goes to court for protection, where, unfortunately, in the vast majority of cases, they face the formal approach of the courts, which do not reveal either the economic essence of the dispute or properly consider the circumstances of a particular case. Taking into account the above circumstances, the authors draw conclusions about the existence of legal gaps in the system of Russian law in the field of taxation, which they propose to fill by fixing the concept of "valid tax obligation" in the relevant Resolution of the Plenum of the Supreme Court of the Russian Federation. As an example of such replenishment, the authors propose to supplement paragraph 7 of the Resolution of the Plenum of the Supreme Commercial Court of the Russian Federation of October 12, 2006 No. 53 "On the assessment by arbitration courts of the validity of the taxpayer's receipt of tax benefits", indicating the need to establish a valid tax obligation of the taxpayer, including personal income tax.

The subject. The modern world is constantly changing, which makes it necessary to update the means and methods of legal regulation of public relations. Moreover, these relations themselves are changing, new areas of public relations are emerging, for which it is necessary to create a legal framework. The sphere of financial and legal regulation is no exception. The most important issue, which has been on the agenda of the international community for several years, is the development of the digital economy. The legal realities of digitalization largely determine what place the Russian economy will occupy in the emerging global digital market. It is necessary to develop a comprehensive legal concept that allows ensuring compliance with the fiscal interests of the state in the context of digital transformation. In this regard, the transformation of tax relations and their legal regulation is particularly important.Purpose of the study. The article is devoted to the transformation of the legal regulation of tax relations in the digital economy. In order for Russian financial and legal regulation to contribute to an effective response to the challenges posed by digitalization, it is necessary to develop a comprehensive legal concept that allows ensuring compliance with the fiscal interests of the state in the context of digital transformation. In this regard, the transformation of tax relations and their legal regulation is of particular importance.Methodology. The research was carried out with the application of the formally legal interpretation of legal acts as well as the comparative analysis of Russian and European legal literature. Structural and systemic methods are also the basis of the research. The main results. The necessity to develop legal solutions in the field of taxation of the digital economy is determined by the focus on legal support for the stability of financial and legal regulation and the principle of certainty of taxation. In these circumstances, it is important to implement the control function of financial law. The need to ensure compliance with the fiscal interests of the state, both at present and in the long term, requires the transformation of essential approaches to the legal regulation of the system of taxes and fees, the principles and elements of taxation, tax administration and tax control. In this regard, it is proposed to provide for special rules for calculating and paying income tax on foreign digital companies and, in parallel, to expand tax incentives for Russian companies.Сonclusions. The authors come to the conclusion that the actual scientific task is to develop a methodological position on the directions of reforming the national tax legislation and the international tax doctrine of the Russian Federation in the context of the digital transformation of public relations. According to the results of the study, it is concluded that it is necessary to ensure compliance with the fiscal interests of the state. This requires the transformation of essential approaches to the legal regulation of tax relations, both in the context of determining the appropriate legal forms for regulating the tax base levied in Russia in the context of the emerging digital economy, and for influencing international tax policy in order to use all the advantages provided by international tax cooperation and neutralize the threats caused by international tax competition.

The idea of progressive tax scale in Russia received a fundamentally new development in 2020. The leading position of the personal income tax in most countries is due to a number of circumstances. First, it is a personal tax, the object of which is the income actually received by the payer, and not the estimated average income that could be received in specific economic conditions. Second, income tax allows to maximize the implementation of the basic principles of taxation – universality and uniformity. In recent decades, national regimes of personal income taxation regimes have been actively developed both in foreign countries and in Russia. Purpose of the study. The article considers the elements of progressive taxation of personal income in the context of the principle of direct and inverse relations. Dealing with selected provisions of the national legislation of European countries and Russia the article shows that elements of progressive taxation can be applied only in particular aspects. The proposals of taxation of rich taxpayers are also brought into light. Methodology. The research was carried out with the application of the formally legal interpretation of legal acts as well as the comparative analysis of Russian and European legal literature. Structural and systemic methods are also the basis of the research, The main results. The establishment of a classical progressive system in the Russian Federation will encourage a change in the model of behavior of both persons who have the opportunity to increase their income, but do not intend to do so due to a decrease in the nominal increase in wages, and persons who previously declared income in full, but if the tax model changes, they will apply personal income tax evasion schemes. In addition, the results of a comparative analysis of the experience of the EU Member States show the ineffectiveness of the progressive income tax scale as a tool to combat social inequality. The comparison provided in the research also examines the problems of proportional and progressive taxation in the context of the principle of equity. In the context of the practice of applying progressive taxation, the experience of foreign countries is studied. Based on foreign experience, it can be concluded that the introduction of family taxation would require a fundamental change in the basis of income taxation in the Russian Federation, as well as would entail discrimination of taxpayers in terms of registered and civil marriage and abuse in order to extract tax benefits. The authors conclude that a more appropriate option for taking into account family circumstances is the widespread use of tax deductions. Since Russian legislation does not establish poverty criteria, personal income tax is levied even on income in the amount of the subsistence minimum. This also does not correspond to the principle of social justice, because in the absence of such criteria, poverty cannot be considered a basis for tax exemption. Thus, the establishment of a classical progressive system in the Russian Federation will encourage a change in the model of behavior of both persons who have the opportunity to increase their income, but do not intend to do so due to a decrease in the nominal increase in wages, and persons who previously declared income in full, but if the tax model changes, they will apply personal income tax evasion schemes. We believe that in the context of the principle of equity, the essence of progressive taxation is not the establishment of several tax rates and is not determined by the number of tax deductions that can be granted only to a small number of persons, including wealthy taxpayers, but that it reflects the ability of a person to pay tax. In our opinion, this ability should be guaranteed by the exemption from taxation of the minimum amount of income (minimum wage). Сonclusions. According to the results of the study, it is concluded that the establishment of a classical progressive system in the Russian Federation will encourage a change in the behavior model of both persons who have the opportunity to increase their income, but do not intend to do so due to a decrease in the nominal increase in wages, and persons who previously declared income in full, but if the tax model changes, they will use personal income tax evasion schemes. In addition, the results of a comparative analysis of the experience of the EU member States show the ineffectiveness of the progressive income tax scale as a tool to combat social inequality. It is proposed to apply only elements of progressive taxation when reforming the Russian tax regime for individuals, namely, to establish a nontaxable minimum in the amount of the minimum wage, which will ensure tax fairness for taxpayers with lower-average incomes.

The subject. The leading position of the personal income tax in most countries is due to a number of circumstances. First, it is a personal tax, the object of which is the income actually received by the payer, and not the estimated average income that could be received in specific economic conditions. Second, income tax allows to maximize the implementation of the basic principles of taxation - universality and uniformity. In recent decades, national regimes of personal income taxation regimes have been actively developed both in foreign countries and in Russia.Purpose of the study. The article shows the results of analysis of the framework of personal income taxation in the Russian Federation in the context of the principle of the social fairness. Dealing with selected provisions of the national legislation of European countries and Russia the article shows that elements of progressive taxation can be applied only in particular aspects. The proposals of taxation of rich taxpayers are also brought into light. Methodology. The research was carried out with the application of the formally legal interpretation of legal acts as well as the comparative analysis of Russian and European legal literature. Structural and systemic methods are also the basis of the research,The main results. After studying the European experience of personal income taxation the authors come to the conclusion that some of the ideas described can be transferred to the Russian tax legislation, but this should be done with caution. It is not necessary to introduce a progressive tax system in its pure form in the Russian Federation, but it is worth considering options for switching to a dualistic system. The authors believe that the elements of borrowing foreign experience should be aimed rather at a fair distribution of benefits, for example, through rules that fix tax benefits.Conclusions. The following proposals can be formulated to improve the legal regulation of personal income taxation in the Russian Federation: the distinction between taxation of taxpayers with ultra-high incomes and those with minimal incomes should be based not on the income criterion, but on the expenditure criterion; to establish a non-taxable minimum in the amount of the minimum wage, which will ensure tax fairness for taxpayers with lower-average incomes; to review the criteria of taxation of luxury vehicles, raising the border separating the mass and premium segments of the Russian car market by at least two times - up to 6 million rubles. The best solution would be to abolish the vehicle tax and impose an increased excise tax on fuel and lubricants for personal transport.