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Blocking Tax Invoices: How Businesses Can Protect Their Rights

Andrii Spektor
Date: 3 Sept , 12:51
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The blocking of tax invoices is one of the most common problems regularly faced by Ukrainian businesses. It creates obstacles in business operations, damages reputation, and may lead to financial losses. Let’s look at why this happens, what consequences it has for entrepreneurs, and how to respond properly.


Why are tax invoices blocked?

The State Tax Service uses risk monitoring algorithms. The most common reasons for blocking include:

  • the company being added to the “risky” list;
  • absence of goods or services specified in the invoice;
  • lack of material and technical capacity or staff to carry out the declared operations;
  • change of product code during production;
  • missing documents for storage and transportation;
  • failure to submit or incorrect completion of the taxpayer’s data table.

Any of these factors can trigger an automatic suspension of invoice registration.


Consequences for business

A blocked tax invoice effectively paralyzes the company’s activity:

  • the taxpayer is listed as “risky”;
  • counterparties cannot obtain a tax credit;
  • the likelihood of additional inspections increases;
  • reputational risks arise.

That is why it is critical to resolve the problem quickly and restore the ability to operate normally.


Administrative procedure for unblocking

The first step is usually administrative appeal to the State Tax Service. Together with the complaint, documents must be submitted to prove that the blocking was unfounded:

  • explanation of the company’s core business activity;
  • contracts and annexes (including foreign trade documentation);
  • primary documents confirming the supply of goods/services;
  • documents confirming the authority of persons receiving goods on behalf of the taxpayer;
  • certificates of product/service compliance;
  • other evidence.


It is important to note: the deadline for filing an appeal is only 10 days from the date of receiving the decision of the State Tax Service.

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Judicial procedure: when the administrative path fails

If the complaint brings no result or the deadlines have been missed, it is possible to appeal to an administrative court.

  • 3 months — if a complaint was previously filed with the tax authority;
  • 6 months — if no complaint was filed.

Court practice shows that judicial proceedings are often the most effective.


Practical tips for businesses

  1. Submit the taxpayer data table. This helps reduce the risk of blocking.
  2. Do not delay action. Every day of downtime means losses.
  3. Consult experienced tax lawyers. Attempts to solve the problem on your own often only waste time.


How much does unblocking cost?

The cost of legal assistance depends on:

  • the number of blocked invoices;
  • the complexity of the case;
  • whether repeated appeals are required;
  • whether administrative or judicial procedure is chosen.

In most cases, the cost of legal support is lower than the losses a business suffers from halted operations.


Conclusion. The blocking of tax invoices is not a death sentence for business, but a challenge that requires qualified legal support. The sooner a company turns to a specialist, the lower its financial and reputational losses will be.

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Andrii Spektor

Andrii Spektor

Bankruptcy and Taxation Attorney

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