How to unlock tax invoices?
The most common reason for disputes between representatives of Ukrainian business and the State Fiscal Service (SFS) is the refusal to register (block) tax invoices (NN) or adjustment calculations (RK) in the Unified Register of Tax Invoices (URNN). If such a task arises as unlocking tax invoices, often the company cannot cope with it on its own.
A team of experienced tax lawyers at Prikhodko & Partners Law Firm offer their assistance in solving this problem. We will be able to quickly understand the reasons for the refusal to register an NN/RK, as well as implement the best way to cancel such a decision of the SFS, which is contrary to the interests of the taxpayer.
What is legal assistance in unblocking tax invoices?
Depending on the reason for blocking NN/RK, lawyers implement several options for actions (separately or sequentially):
Before the administrative appeal of the decision of the SFS body to refuse registration of the NN/RK – collection, preparation and sending of a taxpayer data table, explanations, copies of documents (contracts, acts, and so on).
Administrative appeal – filing a complaint against the decision to refuse registration of the NN/RK to the regional, and sometimes to the central commission of the SFS.
Litigation – filing a claim with an administrative court (since the party to the dispute is the subject of power) and representing the taxpayer in the course of the trial.
For your information! Unblocking of tax invoices is carried out on the basis of:
- Clause 56.1 of the Tax Code;
- Clause 13 of Order No. 520 of the Ministry of Finance 12.12.2019;
- Order No. 1165 Cabinet 12/11/2019;
When is the unblocking of tax invoices carried out through the court?
As a matter of priority, the tax lawyers of Prikhodko & Partners Law Firm are considering options for out-of-court appeal against the refusal to register an NN/RK with the ERNN.
For your information! If the taxpayer chooses the judicial way of resolving the dispute with the SFS, then he can no longer return to the administrative way.
When filing a claim with a court, it is important to comply with the statute of limitations:
- 1095 days from the date of receipt of the relevant decision, and if the complaint was not submitted to the relevant SFS commission;
- 3 months, if a decision was made following the consideration of the complaint;
- 6 months if the decision was not made or was not delivered to the taxpayer.
Important! The court considers exclusively the presence or absence of grounds for refusing to register an NN/RK. The reality of transactions and operations involving the plaintiff cannot be considered within the framework of such proceedings.
If the court makes a decision in favor of the plaintiff and the registration limit has not been exhausted, but, despite this, the SFS refuses to register the NN/RK specialists of Prikhodko & Partners Law Firm are ready to carry out representation in enforcement proceedings, ensuring the execution of the court’s decision through this procedure.
We use all the legal means necessary to help you get back to active business! Andrey Prikhodko
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