To facilitate the work of Ukrainian businesses, the State Tax Service, in particular, has removed almost 10,000 enterprises from the "risky" category since the beginning of the year and reduced the level of blocking of tax invoices to 0.39%. This was announced by the head of the STS, Ruslan Kravchenko, in a column for "Ekonomichna Pravda" and spoke about future plans, UNN reports.
Details
During the war, Ukrainian businesses have to operate in extremely difficult conditions. Constant shelling, loss of assets, relocation, shortage of qualified personnel. These are just some of the problems that entrepreneurs face every day. In addition, many of their complaints concern tax issues.
He noted that the tax service is often perceived as an body that complicates work.
It is quite realistic to change the situation. The main thing is to change the approaches in relations between the tax authorities and taxpayers. To become not an obstacle for them, but a true partner. From the first day in the position of head of the STS, I hear from businesses about the most pressing issues: the suspension of registration of tax invoices and the classification of enterprises as risky. These are acute issues because they affect the economic activity of businesses.
According to him, at the end of 2024, more than 316.2 million tax invoices were registered. The registration of 2.3 million tax invoices was suspended.
SMKOR: expectations and reality
Kravchenko noted that the system for monitoring the compliance of tax invoices with risk assessment criteria (SMKOR) was created precisely for sifting out fictitious transactions, combating tax evasion, and ensuring equal conditions. It is an automated tool for de-shadowing and increasing budget revenues. It automatically detects risky operations and suspends tax invoices.
The situation was exacerbated by a lack of quality communication and clear and transparent rules. Sometimes it is difficult to get an accessible answer as to why an invoice is blocked or why a company has been put on the risky list. Few people fully understand how to prove their integrity. From the outside, it looks like arbitrariness: suspension without reasons, without explanations, without the possibility to defend oneself. A fair system should not work like that.
The head of the State Tax Service noted that live communication with businesses helped identify problems and prompted changes.
A simple and predictable system is what everyone strives for. Businesses should clearly know the algorithms of its operation, the criteria for riskiness, and the procedure for actions in case of invoice blocking. This is about a set of solutions: transparent rules, prompt communication, clear explanations. This approach will allow avoiding corruption risks.
Concrete steps towards change
According to Kravchenko, to qualitatively change the system, analysis is not enough – systematic work and dialogue with those it affects are needed. Together with his team, he met with entrepreneurs from Zhytomyr region, Dnipropetrovsk region, Lviv region, Mykolaiv region, and Odesa region.
Such communication will be in all regions, because only a real dialogue provides an understanding of the correctness of changes. The task of the tax service is not to complicate the life of business, but to promote its transparent and efficient work. At meetings, businesses clearly ask: why do operating companies suddenly find themselves in a dead end and who will help correct the situation?
Kravchenko listed and described specific steps:
- Step one. Communication modernization. To help taxpayers, we have created consulting centers in each region. In total, there are 29 of them, each with five to ten specialists. They promptly advise on how SMKOR works, how to submit data tables, how to exclude a company from the list of risky ones, how to unblock a tax invoice. Consulting centers work simply, accessibly, and clearly;
- Step two. Maximum informing about the need to submit VAT payer data tables. Its absence is one of the main reasons for stopping tax invoices, especially for manufacturing and agricultural enterprises, and service providers. Such a table confirms the reality of economic operations;
- Step three. Decision-making by tax risk commissions – based on comprehensive analysis. The system for determining riskiness must be objective. Commissions make decisions only after a comprehensive analysis of the enterprise's activities;
- Step four. Reduction of bureaucracy. When resolving issues, the tax authority must request a clearly defined list of documents. Businesses massively complained that they had to submit hundreds of pages of documents, often unrelated to the operation or activity of the enterprise. No more "multi-volume works";
- Step five. Enforcement of court decisions. Many contentious issues can be resolved out of court. If a court decision has entered into force, it must be enforced;
- Step six. Clear video instructions. We have created videos with explanations so that entrepreneurs understand each step. They clearly explain how tax invoices and adjustment calculations pass through SMKOR, by what criteria risky payers are identified, and what to do if they fall into this list.
We are open to changes, but they must be based on thorough analysis and understanding of the matter. Each participant in the process must know the sequence and logic of their actions and receive clear feedback.
Results instead of words
The head of the tax service reported that since the beginning of 2025, the number of blocked tax invoices has almost halved.
If at the beginning of January this indicator reached 0.76%, then in mid-March it is 0.39%. At the beginning of the year, every sixth entrepreneur faced blocking, now it is every eighth. At the same time, the list of risky enterprises has decreased by almost 10,000 since the beginning of 2025.
He noted that behind the figures are people, their work, the ability to do business, and retain staff. For some, it took more than a year to get rid of the "risky" status.
For example, one of the enterprises producing petroleum products, according to him, was included in the risky category in September 2023.
All because of transactions with counterparties that turned out to be "risky". After litigation and a won case, the enterprise repeatedly fell into risks due to new reasons. For almost a year, it did not appeal this decision. They decided to get rid of the "risky" status in February 2025. A positive decision was obtained thanks to strict adherence to the recommendations of the tax service.
Kravchenko emphasized that, of course, there are cases when the suspension of registration of tax invoices is fully justified. For example, one of the enterprises declared the cultivation of grain and oilseeds. The company submitted ten tax invoices for the sale of sunflower for registration. Registration was suspended due to the absence of goods.
An analysis of the enterprise's activities showed that 99% of its limit in 2024-2025 was formed due to fuel, and in 2024, with sales of UAH 14.5 million, only UAH 7.7 thousand were paid to the budget. The documents provided to the STS did not confirm the availability of equipment, land cultivation, or grain warehouse balances. Also, inventories of goods not related to agriculture were found. Following the inspection, the STS refused to register the tax invoices.
Kravchenko also gave another example. One LLC provides freight forwarding services. It submitted four tax invoices, registration was suspended due to the absence of goods in stock.
Other problems were also identified: lack of employees for the declared volume of services, the director manages 21 enterprises, tax credit is formed due to the purchase of solvents, gas, and fuel, although transportation services are declared.
In addition, ownership was not reflected in tax and financial statements: cars, warehouses, office, equipment. UAH 110 thousand in taxes were paid with a turnover of UAH 55.7 million. Registration of tax invoices was denied.
What's next
Kravchenko explained the next steps.
First step. The STS has already initiated changes to the mechanism for suspending the registration of tax invoices. Their proposals for changes to government resolution No. 1165 have been submitted to the Ministry of Finance. Currently, they are being processed with ministry specialists. We predict that the changes will reduce the number of blocked invoices.
There are six key changes:
- increased limits for the unconditional registration of invoices by the volume of supply in the current calendar month (second sign). The maximum supply volume will increase to UAH 1 million, and for one counterparty – to UAH 100 thousand. The condition regarding the number of payers where the head can hold a similar position has been changed (currently three, five are planned). Operations with small amounts (up to UAH 10 thousand) will be registered without delays, currently the limit is UAH 5 thousand. The limit of the volume of such operations in the current month will increase to UAH 3 million (currently UAH 500 thousand);
- simplified signs of unconditional registration of tax invoices for export operations for enterprises operating in areas with a threat of hostilities, but where there are currently no active hostilities. Faster processing of invoices for such operations is also planned if the HS codes of such operations match the codes in the taxpayer's data table and the taxpayer is not included in the list of risky ones;
- less bureaucracy after excluding payers from the list of risky ones. Invoices will be subject to automatic registration if the company has a positive tax history and other specified conditions are met;
- improved mechanism for automatic accounting of taxpayer data tables – reducing the need to submit documents for accounting for the table;
- changes in certain indicators of positive tax history – more enterprises will be able to use such indicators. In particular, in the first indicator, the limits of the volume of operations have been increased from UAH 1 million to UAH 3 million, for one counterparty – from UAH 100 thousand to UAH 500 thousand, the condition regarding the number of payers where the head can hold a similar position has been changed (currently three, five are planned);
- changed criterion for the riskiness of operations regarding the submission of adjustment calculations of tax liabilities when returning goods from a non-VAT payer. The submission of such an adjustment calculation within 90 days (currently 30) will not be considered a risk. This will reduce the likelihood of blocking the adjustment calculation when returning goods from a non-payer.
Second step. The STS specified the list of grounds for considering the issue of classifying a payer as risky. The State Tax Service updated the directory of tax information codes. They are used by STS commissions when considering issues of a payer's compliance with taxpayer risk criteria.
Third step. There are also other proposals for improving the organization of SMKOR: a change in the procedure for interaction between structural divisions of the STS at all levels and commissions at the territorial and central levels. This is provided for in the suspension procedure approved by resolution No. 1165.
According to Kravchenko, the following changes are proposed:
- exchange of information on issues of suspension of registration of tax invoices/adjustment calculations between structural divisions of the territorial and central levels;
- operational exchange of information on issues of suspension of registration of tax invoices/adjustment calculations between relevant divisions of territorial bodies of the STS;
- preparation and provision by the central level commission to the territorial bodies' commissions of information based on the results of the analysis of considered complaints to ensure a unified approach when commissions consider similar issues;
- analysis of decisions made by regional level commissions and provision of the results of such analysis to territorial commissions for consideration when considering issues.
The effective operation of SMKOR is related to budget replenishment and is one of the operational tools that prevents schemes and tax evasion. This increases tax revenues and contributes to budget replenishment. For example, in January-February, the STS exceeded the established revenue targets by UAH 22 billion (+16.5% of the plan). We plan to maintain the positive dynamics of the two months in March as well.