Annotation

The aim of this article is to examine the evolving approaches to determining the tax residence of individuals in the context of digital transformation, increasing cross-border mobility, and the growing prevalence of remote work. The relevance of the topic lies in the fact that traditional criteria for tax residence, primarily based on physical presence, are increasingly ineffective in the digital economy. The materials used include OECD recommendations, national legislation of various countries, as well as domestic and foreign academic, expert, and analytical sources. The methodological framework of the study is based on comparative legal, formal legal, and logical methods of analysis. The research identifies key issues associated with traditional residence criteria and their inadequacy in the context of modern digital and cross-border economic activities. It has been established that classical approaches to determining tax residence fail to reflect the actual economic and digital connection of an individual to a jurisdiction. The study concludes that there is a need to revise existing approaches to the tax residence of individuals and to develop internationally coordinated standards that take into account not only digital presence but also the principles of legal certainty, proportionality, and the right to privacy.