Here is the translation of the legal analysis:
1. Subject of Dispute: Challenging a tax notification-decision on applying penalties for late registration of tax invoices.
2. Main Arguments of the Court:
The Supreme Court established that the final deadline for registering tax invoices for February-May 2022 is July 15, 2022, inclusive. The court found the conclusion of previous instances incorrect that the deadline was July 14. For invoices after June 1, 2022, general registration and liability rules apply. The determining criterion is the taxpayer’s ability to timely fulfill obligations.
3. Court Decision: Partially satisfy the cassation appeal, cancel the penalty of 38,808 UAH for the tax invoice dated 13.04.2022, as it was registered on 15.07.2022, which corresponds to the legally established term.
