PROCEDURE FOR STOPPING (BLOCKING) TAX INVOICES

When applying for registration of a tax invoice, the assessment is checked by the CMKOR to assess the risk of violation of tax legislation in the part of forming a fictitious tax credit and tax evasion.

The result of monitoring may be the suspension of tax invoice registration or adjustment calculation, i.e. blocking of tax invoices.
At the same time, the monitoring system performs a step-by-step check of your tax invoice.

It all starts with a check for signs of unconditional registration, if at least one sign matches, registration is taking place, otherwise, a check of the risk criteria of the VAT payer is carried out. If you meet at least one criterion, the tax invoice will be stopped (blocked). If your company is not included in the list of risky ones, in the future CMKOR will check the positive history of the VAT payer and if at least one criterion is met, registration will take place. If not, the riskiness of operations is checked. If the submitted tax invoice/calculation of adjustment does not fall under any criteria, registration takes place, if at least one is performed, such Tax Invoices/ Calculation Adjustments is stopped (blocked).

Currently, the most common reason for stopping (blocking) tax invoices/adjustment calculations is the first criterion, according to which the system (CMKOR) must check the balance of goods on the buyer's "conditional inventory" according to State Tax Service data, i.e. the difference between purchased / imported goods and goods, which are implemented and indicated in the Tax Invoices/ Calculation Adjustments submitted for registration. In the case of exceeding the quantity of sold goods by 1.5 times the remaining goods in the "conditional warehouse", the system must block the Tax Invoices / Calculation Adjustments.

Importantly! Previously, this criterion had to work if more than 50% of the conditional balance consisted of groups of "risky" goods. As of today, this condition has been removed, from now on the "perecourt" will check conditional balances of all goods, not only "risky" ones.

 
In case of stopping the registration of the tax invoice/calculation of the adjustment, a receipt is generated, which is sent during the operating day and must explain which criteria of the taxpayer's risk or risky transactions caused the blocking, contain their calculated values, and also contain DPC's proposals for providing explanations and copies of documents , sufficient for unlocking the tax invoice or calculating the adjustment.

In case of blocking of a tax invoice, the taxpayer has 365 calendar days to provide the State Tax Service with clarifications regarding the unblocking, which shall be calculated from the date of occurrence of the tax liability, which was reflected in such invoice or adjustment calculation.