Theoretical Foundations of Tax Administration and Taxation for Large Taxpayers

This article examines the theoretical foundations of taxation and tax administration for large taxpayers, focusing on the economic, institutional, fiscal, and organizational principles that determine the effectiveness of their interaction with tax authorities. Large taxpayers occupy a strategically important position in national tax systems because their economic activities, financial transactions, employment capacity, investment decisions, and tax liabilities can have a substantial impact on public revenue generation. Consequently, the administration of this taxpayer segment requires approaches that differ from conventional methods applied to small and medium-sized businesses. The study systematizes the main theoretical approaches to large taxpayer administration, including the principles of tax compliance, compliance risk management, taxpayer segmentation, risk-based auditing, voluntary compliance, information exchange, and digital tax administration. Contemporary international practice increasingly emphasizes the identification, assessment, and prioritization of tax compliance risks rather than relying exclusively on traditional tax audits. OECD evidence indicates that large business taxpayers are commonly managed through specialized approaches because of the complexity of their transactions, international activities, tax planning opportunities, and differences between accounting and taxable profits. Particular attention is given to the relationship between taxation principles and the institutional capacity of tax administrations. Effective administration of large taxpayers requires reliable information systems, qualified personnel, analytical tools, transparent procedures, and mechanisms for identifying potentially significant compliance risks. Recent IMF research emphasizes the growing role of data analytics, taxpayer profiling, and analytical case selection in strengthening compliance risk management.