Subject of Dispute: Challenging a Tax Notification-Decision on Imposing a Penalty for Late Registration of Tax Invoices in the Unified Register of Tax Invoices (URPN).
Main Arguments of the Court:
1. The Supreme Court pointed out the need to apply uniform conditions for bringing to liability for late registration of all tax invoices, which were subject to a moratorium until May 27, 2022.
2. The Court recognized that from May 27, 2022, the moratoriums on the application of penalties were terminated, but emphasized the need to take into account the specifics of wartime and the principle of the rule of law.
3. The panel of judges drew attention to the need to verify the correctness of the calculation of penalties and compliance with the principle of non-discrimination of taxpayers.
Court Decision: To cancel the decisions of previous judicial instances and refer the case for a new consideration to the court of first instance for a detailed examination of the case circumstances and verification of the correctness of penalty calculation.
