Any tax invoice (including VAT) registered in the Unified Register of Tax Invoices (hereinafter – URTI), including false ones, participates in the calculation of the registration limit of both the supplier and the buyer. What to do if a false (extra) tax invoice is blocked?
The adjustment calculation can be made only to the registered tax invoice (hereinafter – TI). If the false (extra) TI is blocked, it will not be possible to make an adjustment calculation until it is unlocked and registered.
Usually, in case of suspension of registration of the tax invoice or adjustment calculation in URTI, the controlling body sends (in electronic form in text format) automatically to the value added tax payer (hereinafter – VAT) a receipt confirming the suspension of such registration. The receipt must indicate, in particular, a proposal to provide the taxpayer with explanations and copies of documents necessary to consider the decision of the controlling authority to register the tax invoice/adjustment calculation in UTRI or refuse such registration (items 10, 11 of the Procedure for suspending registration of tax invoice/adjustment calculation in the Unified Register of Tax Invoices, approved by Resolution of the Cabinet of Ministers No. 1165 of December 11, 2019, hereinafter – Procedure No. 1165).
In view of the above, if the controlling authority is not provided with explanations, the issue of unlocking the tax invoice will not be considered.
Therefore, in case of suspension of registration of the false (extra) tax invoice in the URTI, explanations and copies of documents may not be provided. The tax authorities agree with this (category 101.18 “ZIR”). In this case, the tax invoice will remain blocked, and therefore, the adjustment calculation to it will not have to be made.
