The Main Directorate of the State Tax Service in Lviv Oblast draws the attention of taxpayers who have drawn up and/or submitted tax invoices and adjustment calculations for registration in the Unified Register of Tax Invoices to the fact that tax invoices and adjustment calculations which do not meet any of the criteria for automatic registration are checked to ensure that the transactions recorded therein meet the risk criteria for transactions; and if they meet at least one of the taxpayer’s risk criteria, the registration of such tax invoices/correction calculations is automatically suspended by the system.

This is due to the fact that the risk criteria for a business transaction are determined by an automated system, which cannot always take into account the specific features of the production activities of particular enterprises. For example, the registration of tax invoices is very often suspended for enterprises providing services. This is because their purchase structure involves goods, whilst their supply structure involves services; in other words, the so-called risk of substitution of goods or ‘reclassification’ is triggered.

To avoid the suspension of tax invoice registration, a mechanism is provided whereby the VAT payer submits a Taxpayer Data Table, which specifies the UKTZED codes of goods or DKPP codes of services that the enterprise regularly purchases/supplies, with the mandatory attachment of a relevant explanation referencing tax and other reports regarding the actual conduct of its business activities, the availability of the necessary volumes of property and labour resources, technological equipment, etc. Following consideration of such a Taxpayer Data Table and the absence of tax risks, the tax authority’s commission shall decide to accept it, and subsequently the registration of tax invoices for the sale of goods/services under the UKTZED codes for goods or DKPP codes for services specified in the Taxpayer Data Table shall not be suspended.

The taxpayer’s data table is submitted by the taxpayer exclusively in electronic form via electronic means of communication, in accordance with the requirements of the Laws of Ukraine ‘On Electronic Trust Services’, ‘On Electronic Documents and Electronic Document Flow’ and the Procedure for the Exchange of Electronic Documents with Regulatory Authorities, approved by the Ministry of Finance of Ukraine.

Source: Main Department of the State Tax Service in Lviv Region