"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: 3 min.

The agricultural sector of Ukraine is very important not only for providing food for the domestic market, but also for the export direction. Despite the war, the planting campaign has begun, and agricultural enterprises are trying to work at full capacity. However, the activity of Ukrainian agrarians is complicated not only by the conditions of the war and associated risks, but also by some gaps in the direction of regulation of tax issues. The problem of blocking tax invoices is something that businesses in this field of activity often face.

Why is this happening?

There are 2 reasons that lead to the fact that tax invoices are blocked. The first of them is when the LLC is subject to risk criteria, the second is when the economic operation itself is subject to them. The completed tax invoice is checked automatically. The indicators by which this happens are programmed.

Therefore, the program automatically reads data related to price, volume, product characteristics, counterparty and markup. When this ratio seems suspicious to the program, it issues a stop. For example, a stop can be where the margin is greater than 50%. This means that if, for example, the product is sold at a ratio of 1.5 to the existing one, the invoice will be stopped. For example, if you bought 10 bags of raw materials, sold 16, and want to quickly buy 6 more, this will result in the invoice being stopped.

Also, the mentioned factor is influenced by D/P indicators. The specificity of the work of agrarian companies is such that in order to fully provide the crops with everything necessary, it is necessary to purchase fertilizers, gasoline, grain, and agree on the services of land cultivation with the appropriate equipment. It happens that the markup is large, or there is no such product at the entrance, or the volume of supply has increased dramatically, or the codes have changed. There can be many reasons, the system is quite sensitive to them.

How to solve the problem?

There are 2 ways to solve the problem of blocking invoices - administrative and judicial. They are universal, regardless of which sector of the economy the company that faced such a problem operates in. When we talk about the administrative way, we mean the formation of an appropriate explanation and its referral to the DPS. Sometimes companies try to go this way on their own, but as many experiences of our clients show, without quality legal help it usually ends in failure. It is necessary that the case be accompanied by a specialist who has sufficient experience in this category of requests. When the Prikhodko&Partners law firm team tackles this issue, we act as follows:

  • we deeply analyze the state of the enterprise, its assets, industry specifics, tax payment indicators;
  • we study information about counterparties and typical operations;
  • form a comprehensive explanation;
  • we send it to the DPS.

In those cases when the administrative format of solving the problem does not work, we resort to representing the interests of our clients in court, filing an appropriate lawsuit and providing legal support in court.



We use all the necessary legal tools to protect the rights and interests of an agricultural company that has faced the problem of blocking tax invoices - both in extrajudicial and judicial formats. Even in those cases where clients unsuccessfully tried to solve the situation on their own through many attempts, the team of the Prikhodko&Partners law office knows how to act to move the problem from a dead end.

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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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