COMPARATIVE STUDY OF DIGITAL TAX SYSTEMS IN DEVELOPING AND DEVELOPED COUNTRIES

Abstract

Digital transformation has fundamentally changed the global economic landscape, creating new challenges in traditional tax systems. This study examines the comparative implementation of digital tax systems between developing and developed countries, focusing on the regulatory framework, collection mechanisms, and implementation effectiveness. Using a qualitative comparative approach, the study analyzes digital tax practices in several representative countries from both categories, including Indonesia, India, and Brazil as developing countries, and the United Kingdom, France, and Australia as developed countries. The results show that developed countries tend to have more mature digital infrastructure and integrated tax administration systems, enabling more efficient digital tax implementation. In contrast, developing countries face structural challenges such as the digital divide, limited administrative capacity, and resistance from the still-dominant informal sector. However, some developing countries are demonstrating interesting adaptive innovations, such as the use of mobile payment technology and a phased approach to digitizing tax systems. This study concludes that the success of digital tax implementation depends not only on technology adoption, but also on the readiness of the digital economy ecosystem, institutional capacity, and contextual policy design.