The 15th of the 24 months, allocated by the Cabinet for the implementation of the experimental project on the functioning of the system of management of tax risks (compliance) in the State Tax Service (hereinafter-the SUNR, System, Experiment). At the same time, the resolution of the KMU from 25. 07. 24 No. 854 was also accepted for the implementation of the National Strategy of Ukraine's Revenues until 2030 (NSDU).

Note that this attempt to introduce a systemic and automated approach to working with tax risks is not the first, it has been continuing since 2020 and is a non -alternative stage in the activity of the tax authority.

The purpose of the management of tax compliance is the risk management of the four key obligations of taxpayers for registration (registration), timely reporting, submitting the correct reporting indicators and timely payment of tax obligations.

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NSDU expects that the implementation of the system will allow:.

help taxpayers avoid the most common mistakes;

Simplify the submission of tax reporting and payment of taxes as much as possible;

solve problems with joint regulatory authorities and taxpayers;

increase the level of transparency and systematic in the work of the STS;

minimize the risks of non -compliance by payers of tax legislation requirements;

Enter the compliance mechanism from state registration of the taxpayer to the risk system and payment of tax obligations;

ensure the proper receipt of income and fees, minimize the incomplete of obligations according to identified risks and t.

Complete opacity.

I must say that the STS has already adopted a number of orders regarding the system, but they did not make public. In fact, nothing is known about the content of the annual operational plan of the STS for 2025 to improve compliance with tax legislation, sectoral, industry and other plans for the experiment. So the SUNR remains for taxpayers with a black box and a horror story.

We understand that not all aspects of the functioning of the system can be made public, but the complete opacity of the implementation, functioning and operation of the system is unacceptable. It does not even indirectly evaluate the provisions of regulatory acts governing the system, including their compliance with the existing provisions of the Tax Code of Ukraine.

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There is a possibility that certain provisions of these regulatory acts unreasonably expand the existing provisions of tax legislation. In addition, the opacity of the implementation of the system indicates that the STS in practice continues to focus on fiscal-penal methods, and also raises doubts about the effectiveness of its implementation. Oppessancy may also indicate attempts by fiscals to avoid in the future direct responsibility for the selection by a system of taxpayers for checks.

But not one of the expectations of the NSDU given above has yet been justified.

Abeistent episodic messages of the STS on the implementation of the system during 2024 are not an example of effective communication and do not give taxpayers understanding how they need to bring their activities in accordance with the full compliance of the requirements of tax legislation, in terms of tax authorities. While the communication of the STS on the implementation of the system looks like a primitive PR action.

The system is not isolated.

The system is not an isolated information and analytical system. In the future, it should use more and more information in terms of volume and diversity of other ministries and departments, as well as foreign competent authorities.

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Example: In March of this year, the STS, Gosfinmonitoring and BEB reported to intensify the fight against financial crimes, tax evasion, money laundering and financing of terrorism and signed a tripartite memorandum of cooperation. Cooperation will take place in issues of information exchange; creation of working groups for the preparation and conduct of joint events; exchange of experience and providing clarifications regarding the areas of activity.

In May, these same departments have already announced the creation of a joint coordination center for counteracting tax frauds with the prospect of attracting a state service.

O (not) system efficiency.

After the expiration of half the term allotted for the experiment, the taxpayers did not understand what exactly awaits them in practice from the implementation of the system.

The lack of proper communication by the STS and information about real achievements indirectly indicates that the results of the implementation of the system are most likely insignificant.

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We use indented assessment of such effectiveness.

According to information published on July 11, 2025 and. The heads of the GNS of Lesia Karnauh, during the first half of the year 2025, according to the results of cooperation of the STS with law enforcement officers to counteract tax evasion and laundering of funds, more than 156 million UAH of losses were reimbursed and 29 criminal proceedings were registered.

At the same time, the head of the Parliamentary Committee on Finance, Tax and Customs Policy Daniil of the hetmans has repeatedly reported that the shadow sector of the Ukrainian economy is 800-900 billion UAH per year, 30-50% of the economy is in the “shadow”. He emphasized that annual losses only in industries and the turnover of excisable products, household appliances, gambling business reach tens of billions of hryvnias, and even cited schemes.

Comparison of indicators of compensated losses and registered criminal proceedings with the above volume of the shadow sector of the domestic economy, albeit indirectly, but unequivocally raises the effectiveness of the effectiveness, in particular, analytical work and tax authorities, and law enforcement agencies, including the real identification, prevention and elimination of tax risks that have been known for years. The year of the experiment in no way indicates that the implementation of the system had at least some influence on this negative trend.

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A trivial conclusion, but to minimize and/or prevent long -known tax evasion schemes, the elimination of the main players according to these schemes is primarily necessary for the political will of the authorities as a whole and the leadership of the STS, in particular. The system is also needed, but without the first it will continue to remain an instrument of imitation of activities and a primitive PR, mainly designed for external donors.

I also draw attention to the fact that, asserting the need to digitize all the processes of tax administration and control, including the active use of analytical i-solutions, and eliminating the influence of the human factor using the maximum automation of all processes, the STS leadership at the same time introduces a network of consulting centers on the issues of registration of the tax invoice/calculating the adjustment and compliance with the payer and compliance with the payer. Where there is risk focus, digitalization of tax risks and elimination of the human factor?

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