Unlocking tax invoices

What Does the Blocking of a Tax Invoice Mean?

The blocking of a tax invoice means the suspension of its registration in the Unified Register of Tax Invoices (URTI) following automated monitoring by the State Tax Service of Ukraine (STS).

The reasons may include a business transaction meeting risk criteria, the absence of certain goods or service codes in the accepted VAT taxpayer data table in combination with other monitoring conditions, or the company’s classification as a high-risk taxpayer.

After registration is suspended, the taxpayer receives a notification indicating the grounds for the suspension. Analyzing this notification is the first step toward resolving the issue.

Unblocking a tax invoice involves preparing explanations and documentary evidence supporting the business transaction. It is important to examine not only the reason for the suspension but also the primary accounting documents, the specifics of the company’s business activities, and any potential inconsistencies in the tax authority’s position.

Tax Invoice Unblocking Services

Prikhodko & Partners Law Firm provides comprehensive legal support to businesses at every stage of resolving disputes with the tax authorities.

Our lawyers handle both individual blocked tax invoices and complex cases where a company faces systematic suspension of tax invoice and adjustment calculation (TI/AC) registration.

Benefits of Working with Prikhodko & Partners

Our team has practical experience in handling tax disputes and protecting the interests of businesses in their dealings with the State Tax Service of Ukraine.

Why Businesses Choose Us:

• We promptly analyze the reasons for blocking and assess the prospects for successful unblocking.
• We develop an individual legal strategy tailored to the specifics of business transactions.
• We prepare legally substantiated explanations, appeals, and procedural documents.
• We monitor procedural deadlines and manage communication with tax authorities.
• We work remotely with businesses from different regions of Ukraine.

Clients receive a clear action plan, an agreed scope of legal services, and professional support at the designated stages of the procedure.

Tax Invoice Unblocking Procedure

The tax invoice unblocking procedure is regulated by Resolution of the Cabinet of Ministers of Ukraine № 1165 and Order of the Ministry of Finance № 520. Depending on the reasons for blocking, the procedure involves several consecutive stages:

1. Receipt of Notification. The company receives a notification regarding the suspension of tax invoice/adjustment calculation (TI/AC) registration in the Unified Register of Tax Invoices (URTI).
2. Analysis of Blocking Reasons. The applicable risk criteria and documents required to confirm the transaction are identified.
3. Collection of Supporting Evidence. Contracts, invoices, acceptance certificates, bank statements, and other supporting documents are collected.
4. Preparation and Submission of Explanations. Documents are submitted electronically to the State Tax Service (STS) for review by the regional commission.
5. Receipt of a Decision. The commission decides whether to register the tax invoice, refuse registration, or request additional documents.
6. Appeal Against Refusal. In the event of a negative decision, an administrative appeal to the STS or a lawsuit in an administrative court is prepared.

Choosing the appropriate tax invoice unblocking procedure helps avoid unnecessary actions and focus on the documents and legal arguments relevant to the specific case.

Deadlines and Documents Required for Tax Invoice Unblocking

Ukrainian legislation establishes specific deadlines for tax invoice unblocking that must be observed by both taxpayers and the tax authorities.

Written explanations and copies of supporting documents may be submitted within 365 calendar days following the date of issuance of the blocked tax invoice or adjustment calculation (TI/AC).

Within 5 business days after receiving the submitted materials, the regional commission must either issue a decision or request additional explanations and documents. An additional 5 business days are provided for submitting the requested materials in accordance with the established procedure. If a refusal decision is issued, an administrative appeal must be submitted to the STS within 10 business days following the date of that decision.

Depending on the nature of the business transaction, the following documents may be required:

• contracts with counterparties and specifications;
• delivery notes and certificates of completed works;
• goods transportation and warehouse documents;
• payment documents and bank statements;
• documents confirming the origin, purchase, or production of goods;
• other materials confirming that the transaction actually took place.

The final list of required documents depends on the type of business activity, the nature of the transaction, the counterparty, and the grounds for suspending registration. Therefore, before submission, it is important to verify that all necessary documents are complete and that the explanations accurately reflect the actual circumstances.

Stages of Working with a Tax Lawyer

The work of Prikhodko & Partners Law Firm is organized to ensure that clients understand the sequence of actions and the current status of their case.

1. Initial Inquiry and Consultation. The client describes the situation and provides the notification of tax invoice blocking.
2. Legal Analysis. We review the documents, reasons for registration suspension, and existing tax risks.
3. Strategy Development. We agree on the necessary actions, deadlines, and scope of legal support.
4. Preparation of Documents. We prepare explanations, collect supporting evidence, and organize the submission of documents to the State Tax Service (STS).
5. Legal Support Until a Decision Is Issued. We monitor the review process and, if necessary, prepare documents to appeal an unfavorable decision.

Our services are available remotely, without the need to visit our office in person.

Cost of Tax Invoice Unblocking Services

The cost of tax invoice unblocking services is determined individually and depends on the selected scope of services, the number of blocked tax invoices and adjustment calculations (TI/AC), the complexity of the case, the volume of required documentation, and the urgency of the work.

At Prikhodko & Partners Law Firm, you can request a one-time consultation with a tax lawyer or order individual services, including the preparation of explanations, submission of documents, or appealing a refusal issued by the STS. Comprehensive legal support is also available — from analyzing the reasons for blocking to obtaining a decision on tax invoice registration, including judicial appeals when necessary.

After reviewing your situation, our lawyer will recommend the most suitable form of cooperation and agree on the cost of services before work begins.

Conclusion

Unblocking a tax invoice requires timely action, sufficient supporting evidence, and compliance with the established procedure. Errors in explanations or missed deadlines may complicate the restoration of registration and result in additional expenses for the company.

If your tax invoice has been blocked, contact the tax lawyers at Prikhodko & Partners. We will analyze your situation, develop a legal strategy, and provide professional support to protect your business interests.

Have questions? Submit a request on our website, and our lawyer will contact you.