Explanation for unlocking the adjustment calculation

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Yasinskiy Yevhen

Head of tax law practice

An expert in the practice of tax law, specializes in the protection of rights in court, corporate law.

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Explanation for unlocking the adjustment calculation

Reading time: 4 min.

The adjustment calculation is a document submitted by the taxpayer in case there were errors in the tax invoice registered by him or there is a need to make changes. The RC is submitted on the date of the calculation. If we are talking about correcting errors made in mandatory PN details, then such a calculation is made on the date when the error was discovered.

What legislation regulates this issue and what are the consequences of stopping the RK?

With regard to the relevant legal act, here it is worth referring to the Procedure for stopping the registration of a tax invoice/calculation of adjustment in the Unified Register of Tax Invoices. This Procedure was approved by Cabinet Resolution № 1165 dated December 11, 2019. In its paragraph 11, it is said that the receipt for stopping the RK must contain the following information:

  • number and date of drawing up of the RC;
  • the criterion of the riskiness of the taxpayer or business transaction, on the basis of which the RK was stopped in the Unified Register of Tax Invoices;
  • a proposal regarding the taxpayer's provision of explanations, as well as copies of documents in accordance with the Procedure for making decisions on registration/refusal of registration of tax invoices/adjustment calculations in the Unified Register of Tax Invoices.


The consequences of stopping the RK are tangible for the taxpayer. He has difficulties in running his business, and counterparties cannot receive a tax credit. His relations with business partners deteriorate, because cooperation becomes unprofitable. And, of course, this situation leads to fines, if the taxpayer does not provide the explanation required by the representatives of the DPS. Fines are defined in Clause 120-1.2, Clause 90 of Subsection 2 of Chapter XX of the Tax Code of Ukraine.

Therefore, it is important to provide DPS with copies of the necessary documents and written explanations regarding the calculation of the adjustment. These are documents that will confirm the information specified in the RK. Then the commission of the regional level will be obliged to consider the given explanation. This review takes place within 7 working days, which begin on the date of receipt of the payment. Based on the results, a decision is made, which the taxpayer receives in the electronic office on the same day.

What to do if the explanation for unlocking the adjustment calculation is not accepted?

The explanation for unlocking the RK is an administrative way of influencing the situation. And this is an indispensable stage that must be passed before turning to court. However, as our regular practice shows, the result is often achieved later in court. In many situations, the enterprise is included in the list of risky ones without justification, and the position of tax officials is reduced to formalities without proper motivation of the reasons for such a decision. This encourages taxpayers to go to court.

Some decide to go the way of interaction with the DPS on their own, but in the vast majority of cases it does not give results. We were even approached by such clients who made about a dozen attempts to influence the situation themselves and to convey to the tax authorities that there is no real reason to classify neither the company itself nor the economic operations carried out by it in the risk category. However, later it was the professional support that helped move the problem from a standstill.

Specialists in the practice of tax law at the "Prikhodko & Partners" law office will be able to analyze and offer solutions to resolve your issue. To receive professional advice on writing an explanation and unlocking tax invoices - fill out the form on our website and we will contact you shortly.

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