Unblocking tax invoices in court

 YOUR GOAL

You have registered as a VAT payer, started working with partners, and receiving tax credits. But suddenly the tax authority blocked one tax invoice, then another. How to keep working?

How to win a court case against the tax authority regarding tax invoices?

The State Tax Service (STS) refused to register your tax invoices. You may face one of the following situations:

• Blocking due to the taxpayer risk criteria. The tax invoice was suspended because the company was included in the list of “risky taxpayers.” The STS believes the activity may be fictitious.
• Refusal to register the invoice due to lack of supporting documents. Explanations and copies of documents were submitted, but the STS commission rejected them as “insufficient.” Reasons are often formal: absence of certificates, incorrect drafting of contracts, acts, etc.
• Automatic blocking due to goods/services. If the HS Code or NACE code falls into the “risky” category, the invoice is blocked regardless of the actual activity.
• Refusal to register due to mismatch in supply volumes. The monitoring system considers that the supply is not confirmed by stock balances in warehouses.
• Ignoring the taxpayer’s explanations by the STS. Even after providing all supporting documents (contracts, invoices, acts, payment orders), the commission issues a “refusal.”
• Formal errors in documents. Technical inaccuracies in dates, signature mismatches, minor mistakes in consignment notes.
• Delay in the administrative review of a complaint. The taxpayer filed a complaint against the refusal, but the review period was delayed or the decision was again negative.
• Systemic (mass) blocking of invoices. Several invoices of the company are blocked at once, threatening the entire business activity.
• Refusal to register without clear grounds. The STS decision contains standard wording (“failure to provide documents,” “risky taxpayer”) without specifics.
• Blocking of an invoice that affects the buyer’s tax credit. Because of the STS refusal, not only the supplier suffers but also the purchaser, who cannot claim the tax credit.

Then this service is for you!

 OUR OFFER

Unblock tax invoices in court with the help of the legal and accounting company UK EUROVECTOR:

• We analyze the grounds indicated in the refusal.
• We check all documents required for the registration of tax invoices.
• We determine the optimal time limits for filing a claim in court.
• We obtain confirmation of the unblocking of tax invoices.

 PRACTICAL EXAMPLE

Situation: A Limited Liability Company (supplier of construction materials) in August 2024 issued a tax invoice in the amount of 350,000 UAH for its regular client. When the invoice was submitted for registration in the Unified Register of Tax Invoices (URTI), the STS system automatically suspended registration, stating: the company meets the taxpayer risk criteria; there are no confirmed stock balances of goods in the warehouse (according to the SMKOR system). The company submitted explanations and copies of documents: supply contract, delivery notes, payment orders, certificates of conformity. However, the STS commission decided to refuse registration of the invoice, arguing that “the submitted documents do not confirm the reality of the business transaction.” This caused problems: the buyer could not claim the tax credit, the supplier faced fines and the risk of losing business reputation with the client.

Solution: Preparation for a court claim. Analysis of the STS commission’s decision. Collection of additional evidence: consignment notes, quality certificates, acts of completed works, bank statements, warehouse orders. Drafting a statement of claim to the district administrative court. Time limits for filing a claim — it can be filed within 6 months from the date of receiving the STS decision. For challenging blocking of invoices, lawsuits are usually filed within 1–2 months to minimize business losses. The claim requirements: declare the STS commission’s decision unlawful and cancel it; oblige the STS to register the tax invoice in the URTI with the date of its actual submission. Next — court proceedings. The court requested the inspection materials from the STS. It was proven that the buyer really exists, the transaction is confirmed by contracts, acts, payments, and the tax authority did not provide concrete evidence of fictitiousness. The court referred to the legal position of the Supreme Court, which stated that the tax authority must provide clear grounds for blocking, not formal references to “riskiness.” Timeframe: the District Administrative Court considered the case in 2.5 months. The decision was in favor of the company. The STS filed an appeal, but the appellate court confirmed the legality of the decision 1.5 months later.

Result: The court decision came into legal force. The tax invoice was registered in the URTI with the date of its initial submission (retroactively). The buyer was able to claim the tax credit. The company avoided fines and preserved business relations. The total time from invoice blocking to its actual unblocking through the court was about 4 months.

Judicial appeal is an effective way if an administrative complaint does not bring results. It is important to collect as many primary documents as possible and clearly prove the reality of the transaction. In most cases, courts side with businesses if the tax authority does not have concrete evidence of fictitiousness. Contact professionals — we will help prepare and file a claim with the court and assemble the necessary documents to avoid refusals in the registration of tax invoices!

 DOCUMENTS

Documents for a court claim to unblock VAT invoices

In judicial practice, a complete set of primary documents and proof of payment are the main evidence of the reality of a business transaction. If the documents are properly executed – courts usually side with the taxpayer. We will help prepare a document package for VAT registration in accordance with current tax service requirements so that the process is fast and without refusals.

 Price

Unblocking tax invoices through court – service costs and timelines

The cost may vary depending on the complexity of the situation. However, the final result remains unchanged — guaranteed unblocking of tax invoices.

@  ADDRESS

LAW COMPANY EUROVECTOR