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State Tax Administration of Ukraine . Taxation of Small Businesses in Ukraine and Underlying Tax Risks

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State Tax Administration of Ukraine

Taxation of Small Businesses in Ukraine and Underlying Tax Risks

(Current taxation regimes for small enterprises as source of wide-spread practice for tax evasion; Legislative regulation of taxation related issues as element of program for promotion of development of MSE)

Conference on “Taxation of Micro and small Businesses”

May 4 – 6 of 2011, Tbilisi, Georgia


Small business taxation systems


Unified tax for legal and natural persons – subjects involved in economic activities

Flat tax for subjects involved in economic activities – natural persons


Share of proceeds from subjects of economic activities taxed on the basis of simplified tax regime as of 2010


Schemes of tax evasion and minimization of tax payments

  • Splitting of a business;
  • Non-disclosure of proceeds due to failure of accounting or exemption from use of cash registers;
  • Provision of fictitious services
  • - Cashing and etc.

Scheme of provision of fictitious services or cashing

Budget 200 Grivna



Entrepreneur, taxed by simplified regime >> 3

Ordinary company >> 1

Buffer company >> 2

Fictitious services (works)

Fictitious services (works)

Minimization of payments

Withdrawal of 500 Grivna


Scheme of tax evasion through splitting of business

Minimization of tax on income of natural persons and contributions into social funds

Company “a”

Hiring of employees by entrepreneurs, who benefit from simplified tax regime («b»)


Services (works)


Budget loses in tax proceeds around 1 billion Grivna from income tax of natural persons and 2 billion Grivnas in social contributions

Budget 200 Grivnas (2400 Grivnas per year)

Legislative regulation of taxation issues as element of program on promotion of development of small businesses
  • Starting from 01.04.11 the Tax Code prohibits payers of income tax to charge to expenses amounts spent on procurement of goods (works, services) from natural persons, who are taxed by unified tax. (not considered as a deductible expense)
  • “Tax holidays” for small taxpayers, who pay income tax.
  • Simplified system of registration (single window principle, principle of self-declaration)
  • Reduction of licenses and permits for implementation of different types of economic activities
  • Further reformation of simplified taxation system

State Tax authorities of Ukraine

Thank you for your attention

Конференция на тему «Налогообложение микро- и малого бизнеса»

4 – 6 мая 2011 года, Тбилиси, Грузия