TAX SOVEREIGNTY OF THE STATE IN THE CONTEXT OF DIGITALIZATION OF INTERNATIONAL ECONOMIC ACTIVITY
Background: digitalization has a significant impact on the economy. New digital prod ucts, forms of payments appear, the order of interaction between owners of a digital product and its consumers changes. This circumstance requires a change in the legal regulation of economic activity, in particular, changes in tax rules. Existing international tax rules do not take into account the specifics of digitalization of international economic activity. Objective: to identify the main patterns of change in the international tax regulation of the digital economy. To achieve this goal, the article provides an analysis of the various approaches to taxation of the digital economy proposed by the scientific and business communities, and sets out the author’s point of view on this issue. Methodology: analysis of the results of public discussions on the digital economy in the framework of the BEPS project. Results: it has been established that the international tax regulation of the digital economy is developing along the path of unification of international tax rules. Conclusions: there is a tendency towards unification of tax rules, which is directly related to the tax sovereignty of states. Vivid examples of such unification are the establishment of a minimum effective tax rate for income, determining the tax base and rules for accounting for losses. This trend in the absence of physical boundaries for the digital economy seems to be a necessary condition for ensuring the right of the state to establish and levy taxes.