Unblocking VAT Invoices Algorithm Documents and Tips

Unblocking VAT Invoices: Algorithm, Documents, and Tips

Unblocking VAT invoices (tax invoices, hereinafter “TIs”) is a procedure that allows a VAT payer to restore the registration of TIs/adjustment calculations (ACs) in the Unified Register of Tax Invoices (URTI) in case of their suspension due to automated risk monitoring. Below is a step-by-step action plan, a list of required documents, and practical tips for successful unblocking.

Step-by-Step Algorithm for VAT Invoice Suspension

1. Detection of Suspension
   • The taxpayer is notified of the suspension via their Electronic Taxpayer Account. The notification (receipt) contains reasons for the suspension and a list of documents required for unblocking.
2. Analyzing the Reason for Suspension
   • Check whether the company has been assigned a “risky” status and determine which specific data or documents triggered the suspension.
3. Preparing the Document Package
   • Within 5 business days from the date of receiving the notification, prepare and submit written explanations and copies of supporting documents to the State Tax Service (STS) via the Electronic Account.
4. Submission of Explanations and Documents
   • The explanations are submitted along with a Notification of Submission of Explanations (form J1312603 for legal entities). The document package may include contracts, acts, invoices, bank statements, certificates of conformity, etc.
5. Document Review by the Tax Authority
   • The regional commission of the STS reviews the documents within 5 business days and makes a decision to either register or reject the TI/AC. The decision is sent electronically.
6. Appealing a Rejection
   • If rejected, file a complaint with the higher-level STS within 10 business days of receiving the decision. If the rejection is upheld — appeal to the court.

List of Documents for Unblocking

• Written explanations proving the reality of the business transaction
• Copies of contracts, appendices, powers of attorney, acts of work performed
• Primary documents related to the supply/purchase of goods/services (invoices, bills, delivery-acceptance acts)
• Transport documents, warehouse records, inventory reports
• Bank statements, payment orders
• Quality certificates, declarations of conformity (if needed)
• Any other documents proving the actual execution of the transaction

Practical Tips

• Prepare documents thoroughly: Providing a complete set of supporting documents significantly increases the chances of unblocking the TI.
• Respect the deadlines: Meeting the deadlines for submitting explanations and appeals is critical to protecting your rights.
• Use the VAT Payer’s Data Table: Helps avoid future blocking, especially for atypical transactions.
• Automate monitoring: Regularly check the status of your TIs and react promptly to suspensions to avoid penalties and workflow delays.
• Consult professionals: In complex or repeated cases, it’s advisable to engage external consultants or lawyers.

Conclusion

Unblocking VAT invoices is a strictly regulated procedure that requires attention to deadlines, completeness, and the quality of submitted documents. Effective communication with tax authorities, well-prepared explanations and documents, and the use of modern monitoring tools are key success factors.   
And most importantly — consult lawyers who deal with such cases daily and know exactly how to act. Even if your company’s owner or director insists you handle it yourself, remember: this is not an accounting task — it’s legal work. Mistakes during the unblocking process may result in a long journey of appeals — first to the STS, then to the court — which may take anywhere from 2 to 36 months.

The legal firm WINNER is Ukraine’s leading company in unblocking VAT invoices, submitting VAT Data Tables, and removing “risky” statuses — according to the Liga Zakon rating in the “Accountant’s Choice” category. WINNER also ranks among the top Ukrainian firms in tax, criminal, administrative, and commercial law and litigation.

Below is a video lecture titled:         
“Unblocking VAT Invoices, Submitting Data Tables, and Removing Risky Status”
Presented by:
– Maksym Bahniuk, Head of the Tax and Customs Law Practice at WINNER
– Ihor Yasko, Head of the Business Protection Practice at WINNER

Contact: +38 (067) 755-55-13