Abstract: The digital transformation of tax governance is a significant change in promoting the modernization of tax governance, which is of great significance for accelerating the modernization process of the national governance system and governance capacity. Based on the social structure concept, this paper constructs a sociological analysis framework for the digital transformation of tax governance to examine the global tax governance practices. The findings show that the urgency of digital economy development, the intensity of government governance changes, and the intensity of digital technology innovation in various countries have shaped a unique opportunity structure in this transformation process. However, the opportunity structure itself is also in the process of continuous evolution. COVID-19 is the most important external event to promote the opening of its opportunity structure in recent years, while technological alienation is the biggest practical dilemma that leads to the closing of its opportunity structure. China should base itself on its own reality, strive to eliminate the negative impact of digital intelligence technology, maintain the continuous opening of the opportunity structure for digital transformation of tax governance, and promote the modernization of tax governance with high-quality tax digitization. As for the specific path, it is necessary to eliminate tax digital monopoly and tame the tax digital Leviathan, break down the digital tax barriers and improve the efficiency of digital tax governance, bridge the digital gap in taxation and safeguard the digital rights of taxpayers in taxation, and eliminate the internal competition of tax revenue figures and make long-term plans for digital governance.

Key words: digital economy, tax governance, modernization of tax governance, digital transformation, opportunity structure