"Taxes are the price we pay for the opportunity to live in a civilized society".

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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Reading time: 4 min.

Blocking of tax invoices is a problem often faced by Ukrainian enterprises. At the same time, there are mostly no constructive explanations of this phenomenon from the DPS side in the format required by the legislation. So the owners and management of companies have to look for a way to solve such a problem. The company "PRIKHODKO&PARTNERS" knows this method, as clients quite often turn to us with a similar request. Let's consider in more detail why this happens, what consequences the company receives and what to do so that the tax office stops blocking invoices.

Reasons for blocking invoices

The most common reason is item 1 of the Criteria for the riskiness of the transaction - the absence of the product/service specified in the PN submitted for registration in the Unified Register of Tax Invoices (hereinafter - the Register) in the data table of the value added tax payer (hereinafter - the tax payer) as a product /services that are supplied on a regular basis, and the volume of supply of goods/services, specified in the PC/RC to the PN for increasing the amount of tax liabilities submitted for registration in the Register, is equal to or exceeds the amount of the balance; In addition, the tax service checks the virtual balances of goods and, in the event that the sold goods exceed the balances by 1.5 times, it has the right to block the registration of the PN. That is, currently the tax office will check not only the balances of risk groups of goods, but also all others.

When the DPS blocks (stops) invoices, appealing to this point, it offers to provide a comprehensive and complete explanation of the specified economic transaction. At the same time, unfortunately, the receipt on the suspension of the registration of the tax invoice does not contain a specific list of documents that must be submitted in order to make a positive decision.

What does blocking invoices lead to?

Among the consequences is that counterparties are unable to obtain a tax credit. When covering the topic of blocking tax invoices, we always focus on this circumstance, because the mentioned factor entails a number of adverse consequences. Among them is the deterioration of business relations with partners and the loss of those positions on the market that were acquired over a long period of time with hard work.

How to properly prepare an explanation?

The legal company "PRIKHODKO&PARTNERS" has many successful cases of unblocking tax invoices, so we provide you with certain tips, as a rule, to build explanations based on stopped tax invoices:

  • Describe in detail the essence of the business transaction that causes doubt in the tax office. For example, if you have a tax invoice drawn up as a result of the delivery of goods, you must provide documents confirming this. Here it is important that the tax office can trace the origin of this product and its transportation. Of course, various operations have their own industry specifics, so in some cases it is necessary to provide additional information about your company, permit documents, and submit reports to the tax office.

The probability of success in considering such explanations will directly depend on how accurately and in detail you describe everything.


In practice, when clients try to act on their own, in most cases it does not bring the desired result and leads to a waste of time. In addition, in this case, the decision to refuse registration of tax invoices must be appealed in court.

To help our clients, we conduct a detailed analysis of the state of the enterprise, its staff, assets, industry specifics, level of tax payment, counterparties and typical transactions. Based on this, a detailed explanation is prepared for the tax service. So contact us - and we will help.

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Head of tax law practice

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

Contact now
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