Invoice blocking and risky status: Kravchenko spoke about clear solutions instead of chaos

To facilitate the work of Ukrainian business, 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 tax invoices to 0.39%. This was announced by the head of the State Tax Service Ruslan Kravchenko in a column for “Economic Truth” and spoke about future plans, reports UNN.

During the war, Ukrainian business has to work 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. At the same time, many of their complaints concern tax issues 

He noted that the tax service is often perceived as an authority 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 real partner. From the first day as the head of the State Tax Service, I hear from business about the most painful thing: 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 business 

According to him, at the end of 2024, more than 316.2 million tax invoices were registered. Registration of 2.3 million tax invoices was suspended.

SMKOR: expectations and realityKravchenko noted that the screening of fictitious transactions, the fight against tax evasion, ensuring equal conditions – this is what the system of monitoring the compliance of tax invoices with the criteria for assessing the degree of risk (SMKOR) was created for. This is an automated tool for de-shadowing and increasing budget revenues. It automatically identifies risky transactions and suspends tax invoices.

The Tax Service proposes 6 key changes to the invoice monitoring system – Kravchenko03.03.25, 14:41 • 22667 views

The situation was worsened by the lack of quality communication and clear and transparent rules. Sometimes it is not easy to get an accessible answer as to why an invoice is blocked or why a company is on a 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 protect oneself. This is not how a fair system should work 

The head of the State Tax Service noted that live communication with business contributed to the identification of problems and encouraged changes.

A simple and predictable system is what everyone strives for. Businesses should clearly know the algorithms of its operation, the criteria of riskiness and the procedure in case of blocking an invoice. It is about a set of solutions: transparent rules, prompt communication, clear explanations. This approach will avoid corruption risks 

Specific steps to changeAccording to Kravchenko, systematic work and dialogue with those affected by it are needed to qualitatively change the system. Together with his team, he met with entrepreneurs from Zhytomyr, Dnipropetrovsk, Lviv, Mykolaiv and Odesa regions.

Such communication will be in all regions, because only real dialogue gives an understanding of the correctness of changes. The task of the tax authorities is not to complicate the life of business, but to promote its transparent and effective work. At the meetings, business clearly asks the question: why do working companies suddenly find themselves in a hopeless situation and who will help to correct the situation? 

The tax office has reduced the number of enterprises that were classified as risky – Kravchenko17.03.25, 18:30 • 70189 views

Kravchenko listed and talked about specific steps:

⦁ Step one. Modernization of communication. To help payers in each region, we have created consulting centers. 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 remove a company from the list of risky companies, how to unblock a tax invoice. Consulting centers work simply, accessibly, clearly;

⦁ Step two. Maximum informing about the need to submit data tables of the VAT payer. Its absence is one of the main reasons for the suspension of tax invoices, especially in manufacturing and agricultural enterprises, and service providers. Such a table confirms the reality of economic transactions;

⦁ Step three. Making decisions by commissions on tax risks – based on a comprehensive analysis. The risk assessment system must be objective. Commissions make decisions only after a comprehensive analysis of the company’s activities;

⦁ Step four. Reducing bureaucracy. When resolving issues, the tax authorities should request a clearly defined list of documents. Businesses massively complained that they had to submit hundreds of pages of documents, often not related to the transaction or the company’s activities. No more “multi-volume books”;

⦁ Step five. Execution of court decisions. Many controversial issues can be resolved in pre-trial proceedings. If the 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 explain in an accessible way how tax invoices and adjustment calculations are processed in SMKOR, according to which criteria risky payers are determined, and what to do in case of getting into this list.

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

Results instead of wordsThe head of the tax service informed that since the beginning of 2025, the number of blocked tax invoices has almost halved.

If at the beginning of January this figure reached 0.76%, then in mid-March it is 0.39%. At the beginning of the year, every sixth entrepreneur faced blocking, now – 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 numbers are people, their work, the opportunity to do business, to maintain staff. Some people needed more than one year to get rid of the “risky” status.

For example, one of the enterprises that produces oil refining products, according to him, was included in the category of risky in September 2023.

All because of transactions with counterparties who turned out to be “risky.” After the court proceedings and the won case, the company repeatedly fell into risks for 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 received thanks to clear adherence to the recommendations of the tax authorities 

Kravchenko stressed that, of course, there are examples when the suspension of registration of tax invoices is fully justified. For example, one of the enterprises declared the cultivation of grain and oil crops. The company submitted ten tax invoices for registration regarding the sale of sunflower. Registration was suspended due to the lack of goods.

The analysis of the company’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 was paid to the budget. The documents provided by the State Tax Service did not contain confirmations of the availability of equipment, land cultivation or warehouse stocks of grain. Stocks of goods not related to agriculture were also found. Following the audit, the State Tax Service refused to register tax invoices 

Kravchenko also gave another example. One of the LLCs provides freight forwarding services. It submitted four tax invoices, registration was suspended due to the lack of goods in the warehouse.

Other problems were also found: the lack of employees for the declared volume of services, the director manages 21 enterprises, the tax credit is formed due to the purchase of solvents, gas and fuel, although transportation services are declared.

In addition, the tax and financial statements do not reflect ownership: cars, warehouses, offices, equipment. UAH 110 thousand of taxes were paid with a turnover of UAH 55.7 million. Registration of tax invoices was refused 

Kravchenko: The State Tax Service supports business in Kharkiv region by reducing the number of blocked tax invoices21.03.25, 17:47 • 17447 views

What’s nextKravchenko explained the next steps.

The first step. The State Tax Service has already initiated changes to the mechanism for suspending the registration of tax invoices. Their proposals for changes to government decree No. 1165 were submitted to the Ministry of Finance. We are currently working on them with specialists from the Ministry. We predict that the changes will reduce the number of blocked invoices. There are six key changes:

⦁ increased limits for the sign of unconditional registration of invoices by the volume of supply in the current calendar month (second sign). The maximum volume of supply will increase to UAH 1 million, and to one counterparty – to UAH 100 thousand. The condition regarding the number of payers where the manager can hold a similar position has been changed (now three, five are planned). Transactions with small amounts (up to UAH 10,000) will be registered without delay, now the limit is UAH 5,000. The limit of the volume of such transactions in the current month will increase to UAH 3 million (currently UAH 500,000);

⦁ 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 no active hostilities at the moment. It is also planned to speed up the processing of invoices for such operations if the FEA codes of such operations coincide with the codes in the taxpayer’s data table and it 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 defined conditions are met;

⦁ improved mechanism for automatic accounting of the payer’s data tables – reducing the need to submit documents for accounting of 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 transactions are increased from UAH 1 million to UAH 3 million, to one counterparty – from UAH 100,000 to UAH 500,000, the condition in the part of the number of payers where the manager can hold a similar position is changed (now three, five are planned);

⦁ the criterion of riskiness of operations regarding the submission of adjustment calculations of tax liabilities when returning goods from a non-VAT payer has been changed. 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 an adjustment calculation when returning goods from a non-payer.

The second step. The State Tax Service has specified the list of grounds for considering the issue of classifying a payer as risky. The State Tax Service has updated the directory of tax information codes. They are used by the STS commissions when considering the issue of the payer’s compliance with the criteria of riskiness of the taxpayer.

The third step. There are also proposals to improve the organization of SMKOR: a change in the procedure for interaction between structural units of the State Tax Service at all levels and commissions of 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 the suspension of registration of tax invoices/adjustment calculations between structural units of the territorial and central levels;

⦁ prompt exchange of information on the suspension of registration of tax invoices/adjustment calculations between the relevant units of the territorial bodies of the State Tax Service;

⦁ preparation and provision by the central level commission to the commissions of the territorial bodies of information based on the results of the analysis of the considered complaints to ensure a unified approach when considering similar issues by the commissions;

⦁ analysis of decisions made by regional level commissions and provision of the results of such analysis to territorial commissions for consideration when considering issues.

“We are working to ensure that the tax administration system of Ukraine is more transparent and efficient” – Kravchenko20.03.25, 12:28 • 9675 views

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 State Tax Service exceeded the established revenue targets by UAH 22 billion (+16.5% to the plan). We plan to maintain the positive dynamics of two months in March as well