“No more “multi-volumes”: Ruslan Kravchenko explained how the tax service reduces pressure on business

The problems of taxation in wartime have become one of the key topics for Ukrainian business. Constant risks associated with shelling, loss of assets, relocation, shortage of qualified personnel create extremely difficult conditions for conducting business activities. But no less a problem for business remains the complex and confusing tax system, in particular the issue of blocking tax invoices and classifying enterprises as risky.

Head of the State Tax Service of Ukraine Ruslan Kravchenko noted, that during the war Ukrainian business has to work in extremely difficult conditions. He emphasized that constant shelling, loss of assets, relocation, shortage of qualified personnel are only part of the problems faced by entrepreneurs every day. In addition, many of their complaints relate to tax issues. According to him, the tax service is often perceived as a body that complicates the work. He emphasized that it is quite possible to change the situation. The main thing is to change approaches in relations between the tax office and taxpayers. He stated that it is necessary to become a true partner for business, not an obstacle.

Ruslan Kravchenko said that from the first day as head of the DPS, he heard from businesses about the most painful thing – the stoppage of registration of tax invoices and the classification of enterprises into the risk category. He noted that these are acute issues, because they affect the economic activity of businesses. At the end of 2024, more than 316.2 million tax invoices were registered. Registration of 2.3 million tax invoices has been suspended. He reminded that the screening of fictitious transactions, the fight against tax evasion, ensuring equal conditions — precisely for this purpose, the system for monitoring the compliance of tax invoices with the criteria for assessing the degree of risk (SMKOR) was created. Ruslan Kravchenko emphasized that this is an automated tool for detinization and increasing budget revenues. He explained that the system automatically detects risky transactions and stops tax invoices.

At the same time, he noted that the situation was worsened by the lack of quality communication and clear and transparent rules. According to Ruslan Kravchenko, sometimes it is not easy to get an affordable answer as to why the invoice is blocked or why the company is on the risk list. He emphasized that few people fully understand how to prove their integrity. According to him, from the side it looks like arbitrariness: a stop without reason, without explanation, without the possibility to defend oneself. This is not how a fair system should work. Live communication with the business contributed to the identification of problems and prompted changes. Ruslan Kravchenko emphasized that a simple and predictable system is what everyone wants. He stated that the business should clearly know the algorithms of its work, risk criteria and the procedure for blocking the invoice. According to him, it is about a set of solutions: transparent rules, prompt communication, clear explanations. He emphasized that such an approach will avoid corruption risks.

The head of the State Tax Service emphasized that in order to qualitatively change the system, analysis is not enough — systemic work and dialogue with those affected by it are needed. He stated that he and his team 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 gives an understanding of the correctness of the changes.

“I am the same taxpayer as all citizens of Ukraine, and a strong economy is our common goal. At meetings, business clearly asks the question: why are working companies suddenly at a dead end and who will help to correct the situation?”, – Kravchenko wonders.

He said that the first step in solving this situation is to modernize communication. Ruslan Kravchenko said that consultation centers have been created in each region to help taxpayers. There are 29 of them in total, each with five to ten specialists. He emphasized that they promptly advise on how SMCOR works, how to submit data tables, how to exclude a company from the list of risky ones, how to unlock a tax invoice. Ruslan Kravchenko emphasized that the consultation centers work simply, easily, and clearly.

The second step, he called maximum informing about the need to submit VAT payer data tables. According to Ruslan Kravchenko, its absence is one of the main reasons for the suspension of tax invoices, especially in manufacturing and agricultural enterprises, enterprises providing services. He explained that such a table confirms the reality of economic transactions.

Ruslan Kravchenko emphasized that the third step is the adoption of decisions by tax risk commissions based on a comprehensive analysis. He emphasized that the system for determining riskiness should be objective. According to him, commissions make decisions only after a comprehensive analysis of the company’s activities.

He said that the fourth step is the reduction of bureaucracy. Ruslan Kravchenko noted that the tax department should ask for a clearly defined list of documents when resolving issues. He emphasized that businesses complained en masse that they had to submit hundreds of pages of documents, often not related to the operation or activities of the enterprise.

Ruslan Kravchenko emphasized: “No more “multi-volume” books.

He stated that the fifth step is the implementation of court decisions. According to him, many controversial issues can be resolved in a pre-trial procedure. Ruslan Kravchenko emphasized that if the court’s decision has gained force, it must be implemented.

He said that the sixth step is clear video instructions. According to him, the tax office has created videos with explanations so that entrepreneurs understand each step. He noted that they clearly explain how tax invoices and adjustment calculations are processed in SMCOR, what criteria are used to determine risky payers and what to do in case of getting on this list.

Ruslan Kravchenko emphasized:

“We are open to changes, but they should be based on careful analysis and understanding of the essence of the matter. Each participant in the process should know the sequence and logic of their actions and receive clear feedback.”

He noted that there are already results instead of words. According to him, 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 the middle of March it is 0.39%. At the beginning of the year, every sixth entrepreneur encountered a blockage, now every eighth. At the same time, according to him, the list of risky enterprises has decreased by almost 10,000 since the beginning of 2025. Behind the numbers are people, their work, the opportunity to do business, to keep staff. For some, it took more than one year to get rid of the “risky” status.

Kravchenko gave an example when one of the enterprises producing oil refining products was included in the risky category in September 2023. All because of transactions with counterparties that turned out to be “risky”. After a lengthy court case and a successful case, the company again found itself at risk due to new reasons, and it did not appeal this decision for almost a year. They decided to get rid of the “risky” status in February 2025, a positive decision was obtained thanks to strict compliance with the recommendations of the tax office.

Ruslan Kravchenko gave another example – an agricultural enterprise that became “risky” in April 2024. He explained that the reason was the lack of labor resources and the lack of operations that would confirm the real cultivation and supply of products. Although the company submitted reports of non-compliance with risk criteria during the year, the documents lacked strong evidence. In February 2025, the company received specific recommendations from the tax office and provided comprehensive confirmation of its activities. The result is exclusion from the risk list.

Here is another case. The transport company was faced with the blocking of tax invoices due to the discrepancy between the volumes of supply and the purchase of services. The tax office has repeatedly rejected submitted data tables due to the lack of explanations and documents. He noted that the company received detailed recommendations and correctly issued documents — fixed assets, labor resources, permits, technical passports. This made it possible to unlock the invoices and prevent further stops in their registration.

Kravchenko noted that the analysis of the company’s activities showed that 99% of its limit in 2024-2025 was formed thanks to fuel, and in 2024, with the realization of 14.5 million UAH, only 7.7 thousand were paid to the budget. UAH In the documents provided by the DPS, there were no confirmations of the availability of equipment, land treatment or grain storage residues. Stocks of goods not related to agriculture were also discovered. Ruslan Kravchenko emphasized that according to the results of the inspection, the DPS refused to register tax invoices.

The head of the State Tax Service about its future ways. The first step — the DPS has already initiated changes to the mechanism for stopping the registration of tax invoices. He stated that his proposals for changes to Government Resolution No. 1165 were submitted to the Ministry of Finance. They are currently being worked on with the Ministry’s specialists. He predicts the changes will reduce the number of blocked invoices. According to him, there are six key changes:

1. Increased limits for the feature of unconditional registration of invoices by the volume of supply in the current calendar month (second feature). The maximum supply volume will increase to 1 million hryvnias, and to 100,000 hryvnias per counterparty. UAH The condition regarding the number of payers where a manager can hold a similar position has been changed (currently three, five are planned). Transactions with small amounts (up to UAH 10,000) will be registered without delay, currently the limit is UAH 5,000. UAH The limit of the volume of such operations in the current month will increase to UAH 3 million (currently UAH 500,000).
2. Simplified signs of unconditional registration of tax invoices for export operations for enterprises operating in territories with a threat of fighting, but where there is currently no active fighting. It is also planned to speed up the processing of invoices for such operations, if the UKTZED codes of such operations match the codes in the taxpayer’s data table and he is not included in the list of risky ones.
3. Less bureaucracy after exclusion of payers from the list of risky ones. Invoices will be automatically registered if the company has a positive tax history and other specified conditions are met.
4. An improved mechanism for automatic inclusion of payer data tables — reducing the need to submit documents for table inclusion.
5. Some indicators of a positive tax history are changing — more companies will be able to use such indicators. In particular, in the first indicator, the transaction volume limits were increased from UAH 1 million to UAH 3 million, from UAH 100,000 per counterparty. UAH up to 500,000 hryvnias, the condition has been changed regarding the number of payers where the head can hold a similar position (currently three, five are planned).
6. The criterion of the riskiness of transactions regarding the submission of tax liability adjustment calculations upon the return of goods from a non-payer of value added tax is being changed. Submission of such an adjustment calculation within 90 days (currently 30) will not be considered a risk. This will reduce the probability of blocking the adjustment calculation when the goods are returned from the non-payer.

According to Kravchenko, the second step is the following — DPS specified the list of grounds for consideration of the issue of classifying the payer as risky. The State Tax Service has updated the directory of tax information codes. They are used by DPS commissions when considering questions about the taxpayer’s compliance with the criteria of the taxpayer’s riskiness.

The third step is to improve the organization of the work of the SMCOR: a change in the order of interaction between the structural units of the DPS of all levels and the commissions of the territorial and central levels. This is provided for in the suspension procedure approved by Resolution No. 1165.

“We propose such changes.

1. Exchange of information on issues of suspension of PN/RK registration between structural subdivisions of the territorial and central levels.
2. Prompt exchange of information on the suspension of PN/RC registration between the relevant divisions of the territorial bodies of the DPS.
3. Preparation and provision by the commission of the central level to the commissions of territorial bodies of information based on the results of the analysis of the reviewed complaints to ensure a unified approach when the commissions consider similar issues.
4. 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 work of the SMCOR is related to filling the budget and is one of the operational tools that prevents schemes and tax evasion. This increases tax revenues and contributes to filling the budget. For example, in January-February, DPS exceeded the established revenue indicators by UAH 22 billion (+16.5% to the plan). We plan to maintain the positive dynamics of two months in March as well.” – said Kravchenko.