What question did this study set out to answer?

This article aims to explore the legal nature and structure of tax legal relations in Ukraine amidst current socio-political changes.

April 14, 2026Open Access

The Comprehensive Nature of Taxation Relations

OHOksana HindaCourt of Appeal MKMykola KucheriavenkoYaroslav Mudryi National Law University ASAndrii SalenkovYaroslav Mudryi National Law University

Key Points

This article aims to explore the legal nature and structure of tax legal relations in Ukraine amidst current socio-political changes.
Analysis of tax legal relations through a legal framework in Ukraine
Examination of the impact of war, digitalisation, and European integration
Assessment of structural components including subjects, objects, and content of tax law
Clarified distinctions between tax establishment and taxpayer obligations
Highlighted the dynamic nature of tax legal relations
Identified the role of war and digitalisation in shaping tax structures
Outlined the necessity for coherent legal regulation for financial stability

Abstract

Tax legal relations constitute a specific and highly structured category of social relations, characterised by the fact that they can only emerge in legal form. The complex social, economic, technological and geopolitical circumstances that influence modern taxation processes in Ukraine necessitate a thorough examination of their legal nature. This article explores the essence, structure and composition of the subjects of tax legal relations, focusing on the mechanisms through which taxes acquire their legal status. A tax obligation arises only once a tax has been legislatively established and properly introduced. This creates a clear distinction between the establishment of a tax (its definition within the Tax Code of Ukraine) and its introduction (when the taxpayer becomes legally bound to fulfil the corresponding obligations). The study emphasises that contemporary tax relations cannot be adequately understood without considering three key factors: the impact of the war with Russia on both taxpayers and the subjects of taxation; the rapid digitalisation of public administration, which increases transparency significantly and reduces the risk of corruption; and Ukraine’s steady progress towards European integration, which is shaping the modernisation of tax legislation. This text focuses on the structural components of tax legal relations, namely their object, subjects, and content. The article demonstrates the necessity of distinguishing between the object of taxation and the object of the legal relation, as well as between subjects of tax law (potential participants) and subjects of tax legal relations (actual participants). The inherent inequality between authoritative and obligated subjects is shown to be an objective feature of public-law relations. The research under discussion highlights the dynamic character of tax legal relations and the growing importance of their coherent legal regulation in ensuring the financial stability and institutional capacity of the Ukrainian state.

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