The state tax service has clarified what it wants to see from businesses to avoid VAT invoice suspension

On 27 August, the State Tax Service of Ukraine again drew businesses’ attention to practical guidance on completing the VAT Taxpayer Data Table. The recommendations were developed on the basis of actual business inquiries and common taxpayer mistakes.

The important point is not only the Data Table itself.

In effect, the State Tax Service is showing businesses what information it expects to see in order to understand the company’s genuine operating model.

The Data Table specifies NACE activity codes, товар codes under the Ukrainian Classification of Goods for Foreign Economic Activity, and service codes under the State Classifier of Products and Services. However, the table alone is not sufficient: it must be accompanied by an explanation of the company’s activities, with references to tax and other reporting.

Moreover, the State Tax Service provides specific examples of circumstances in which the Data Table may not be taken into account.

For example, a company declares freight transportation activities but has no owned or leased vehicles, does not purchase fuel, does not report the relevant facilities in Form 20-OPP, or cannot adequately explain its business transactions.

Therefore, VAT invoice suspension is no longer merely a matter of completing a document correctly.

The State Tax Service effectively compares what a business declares with whether it has real resources to carry out the stated activities.

For this reason, the VAT Taxpayer Data Table should not be treated as a formality to be completed only after another VAT invoice has been suspended. It should be regarded as part of a properly structured tax position for the business.

It is better to prepare the Data Table while the company is operating normally than to start collecting documents after the registration of VAT invoices has been suspended.

Source: State Tax Service of Ukraine, 27 August 2026.

Author – Maksym Bahniuk, Head of Tax and Customs Law Practice at Law Firm “WINNER”.
Contact: info@uk-winner.com | +38 (096) 574 81 02