SUSPENSION OF REGISTRATION OF TAX INVOICES

Today we will talk about topical issues on the border of accounting and taxation. And the topic of conversation will be the well-known value-added tax, or more precisely, the related situations of stopping the registration of tax invoices and classifying the business entity as risky.

Recently, there have been more frequent situations not just of stopping the registration of tax invoices, but of classifying a business entity as risky (one that meets the riskiness criteria of the taxpayer). And if there are not many problems with stopping the registration of a tax invoice (you only need to write an explanation about the transaction and attach a minimum package of primary and other documents), then recognizing the subject as risky actually paralyzes economic activity.

We would like to remind you that the risk criteria of a value-added tax payer are an appendix to the Procedure for stopping the registration of a tax invoice/calculation of adjustment in the Unified Register of Tax Invoices, which was approved by Resolution № 1165 of the Cabinet of Ministers of Ukraine dated December 11, 2019. You can familiarize yourself with them on the official web portal of the parliament by following the link.

In total, there are 8 risk criteria. However, the most common is item 8, which is unspecified and abstract.

Attribution of a business entity to risk has a direct impact on accounting. First of all, all tax invoices that are submitted for registration after such a decision has been made by the Main Department of the State Tax Service in your region (or the city of Kyiv) - are not automatically registered.

That is, for each tax invoice you need:

• Write an explanation about the operation;
• Bounce all the documents that are described in the explanations;
• Download, sign the EDS and send everything through the electronic cabinet to the DPS body;
• Wait seven working days to receive a decision on registration or refusal to register the invoice.

I will immediately note that almost all of the above-mentioned work refers to the duties of an accountant. Therefore, it is necessary to clearly systematize all available documents and reflect the process in the explanations. We note that the minimum acceptable package of documents to obtain a positive result is copies of:

• Supply contract, specifications;
• Payment orders;
• Expense invoice;
• Powers of attorney to receive trade material values;
• Act of provision of services;
• Bill of lading, etc.

As for the riskiness of the entity itself, it is necessary to pay attention to the reason for classifying it as risky, which is directly stated in the decision of the supervisory body. After processing this information, we collect the entire available package of documents, refute the opinion of the controllers and similarly submit an explanation through the electronic cabinet.

I also want to note that it is strictly forbidden to delay this process, as it will only accumulate problems. Therefore, it is necessary to involve the entire staff as much as possible and submit an explanation with copies of documents.

The accountants and lawyers of the legal company "Prikhodko&Partners" know how to register all tax invoices without exception and exclude a business entity from risky ones. Contact us, we will be happy to help you.