Automated tax regimes for self-employed: a comparative analysis of pioneering systems in Estonia and Ukraine

Micro-enterprises are among the most vulnerable business entities in terms of tax compliance. To lower entry barriers for self-employed entrepreneurs, many countries have introduced simplified tax regimes based on presumptive or turnover taxation. The ongoing digitalisation of the tax sector and the advent of “real time economy” have enabled the development of automated tax regimes—that is, regimes under which taxpayers have no obligation to file tax declarations manually and tax liabilities are instead calculated automatically by authorities or authorised intermediaries on the basis of real transaction data rather than fixed presumptions. This research employs a comparative methodology that combines functional and common-core approaches. Through a comparative analysis of pioneering systems in Estonia and Ukraine, shared legal features are identified, critically evaluated, and synthesised into a “minimal formula” for automated taxation. The resulting framework is intended to support policymakers in advancing efficient and inclusive tax digitalisation.