This study aims to review how the efforts of the tax authorities to tax digital transactions to improve tax compliance. This research is a review of the provisions and regulations related to digital transactions. The review uses three approaches of historicity, rationality, and policy actuality based on the values of Pancasila as the source of all sources of law. The research results are divided into three levels of policy review. At the level of historicity, digital transactions with traditional transactions have the same tax obligations. At the level of rationality, digital transactions are transactions across jurisdictional borders, the aspect of income tax taxation requires criteria for determining permanent establishment. At the level of actuality, tax authorities are required to carry out unilateral measures and global consensus refers to the provisions of the OECD and the hierarchy of tax laws. The value of Pancasila justice is the foundation of the proposed tax policy that balances the obligations of foreign tax subjects with domestic tax subjects through the concept of significant economic presence. This research contributes practically to tax authorities in formulating digital transaction tax collection policies so that they can improve tax compliance.