To the Prime Minister of Ukraine
Minister of Economy of Ukraine
Minister of Finance of Ukraine
Heads of the Committee on Finance of the Verkhovna Rada of Ukraine, tax and customs policy
Heads of the Committee of the Verkhovna Rada of Ukraine on Economic Development
Members of the Ukrainian Business Council Coalition, which includes 105 business associations of various sectors of the economy, express their respect to you and address you as follows:
Recently published conclusions investigation of the Business Ombudsman Council regarding the operation of the SMKOR system. The key conclusions of the Council are::
- IN 4 quarters 2022 Year of blocking touched 65 tis TOV, what is 40,4% from active VAT payers.
- Time spent on unlocking PN is more 12 hours of time of the accountant/director.
- During the operation of the system, it was eliminated 2/3 gray schemes, but now the system is not working optimally - there is more manual mode, broader and less clear criteria, the mass of blockages, improper justification of DPS decisions.
- Close 95% court cases regarding blockages - taxpayers will win.
Based on the results of the investigation, the Council of the Business Ombudsman made the following proposals, to fix the system:
- Improve risk orientation, clearer criteria, more automation
- Make a real analysis of the regulatory impact of the system, real calculations (additional revenues to the state/business expenses)
- Build the system's fuses - the system must first warn the payer
- Allow admins to challenge tables
- Provide information on the risks of counterparties, remove risk "retrospectively"
- Publish more statistics on key system indicators