Blocking of tax invoices 2023

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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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Blocking of tax invoices 2023

Reading time: 4 min.

Blocking of tax invoices in most cases occurs when representatives of the State Tax Service see risk criteria in any of the economic transactions being carried out. In fact, in many situations, such a reason is formal, and the actions of tax officials look like abuse. However, as practice shows, the administrative method of solving the problem by writing a reasoned explanation of one’s position to the State Tax Service in the vast majority of cases does not help. Therefore, it is necessary to defend the rights and legitimate interests of the company in court. Again, this can be extremely difficult to do without the relevant knowledge. That is why, ultimately, company representatives mostly turn to lawyers.

Blocking of tax invoices 2023 - information deskWhat does the situation with the blocking of tax invoices look like in practice?

The norms of the current legislation oblige tax officials to motivate their decision regarding what exactly they see as the riskiness of an economic operation. However, this is how it looks ideally. In practice, you can see a completely different situation, when the fact of blocking exists, but there is no full explanation that would not look like a formal unsubscribe. In addition, the invoice registration system itself works imperfectly, as many business representatives were able to verify. Sometimes a combination of indicators is activated, according to which a business transaction that is not really risky is automatically identified. As a result, the invoice is blocked, and the business suffers.


Blocking of tax invoices 2023 - team informationWhy you should go to court and what happens if you delay?

Unfortunately, such a situation cannot be resolved on its own. The problem not only does not disappear, but also causes a number of other complications. The first of them is that the usual economic activity of the company stops. Another consequence is the deterioration of relations with counterparties. If your invoices are blocked, partners are not able to claim a tax credit. Thus, your problem automatically becomes the problem of other market participants who would like to cooperate with you.

So there is only one reasonable solution here – to start standing up for your company’s rights as early as possible, without waiting for the negative consequences of inaction to accumulate and harm your business even more.

Blocking of tax invoices 2023 - urb 9864 1

Blocking of tax invoices 2023 - judgmentHow the court is held?

As for the jurisdiction of such cases, they are under the jurisdiction of the district administrative courts, which may be based on the location of the plaintiff or the defendant. This is determined on the basis of Art. 19 KASU. As for the stages of the proceedings, they are as follows:

  • initiation of a case and corresponding investigation;
  • consideration, decision in the case;
  • possible appeal of the decision by the parties;
  • implementation of the decision.

Blocking of tax invoices 2023 - group protectionLawyers of the “Prikhodko&Partners” law office regularly represent the interests of clients in such cases. Unfortunately, the situation with unjustified blocking of tax invoices happens very often, so it is necessary to protect the rights of client companies so that such actions of tax officials do not endanger the normal functioning of business and relations with partners.


During our activity, we have developed reliable algorithms and know how to help you qualitatively. Such cases are win-win if the representation strategy is approached correctly. And the team of our law office knows how to do it.

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