Here is the translation:
1. Subject of Dispute: Challenging a tax notification-decision on applying penalty sanctions for late registration of tax invoices.
2. Main Arguments of the Court:
– For tax invoices prepared before February 1, 2022, and registered until July 15, 2022, penalty sanctions are not applied.
– For tax invoices prepared in October 2022, general rules of registration and penalties under paragraph 120-1.1 of Article 120-1 of the Tax Code apply.
– Provisions on reduced penalties (paragraphs 89-90 of subsection 2 of section XX of the Tax Code) cannot be applied to legal relations that arose before their entry into force.
3. Court Decision: Partially satisfy the cassation appeal, cancel the decisions of previous instances regarding the application of penalties for October tax invoices, and adopt a new decision to reject the claim.
Note: The court clearly defined the temporal boundaries for applying various norms on penalties for late registration of tax invoices.
