Here is the translation:
1. Subject of Dispute: Challenging tax notifications-decisions on penalties for late registration of tax invoices in the Unified Register of Tax Invoices (URTI).
2. Main Court Arguments:
: The court essentially changed its previous position regarding the application of penalties for late registration of tax invoices.
– A moratorium on penalties was in effect from March 1, 2020, to May 26, 2022
– After May 26, 2022, controlling authorities can apply penalties
– For invoices issued from February 1 to May 31, 2022, a preferential registration period until July 15, 2022, is provided
– Penalty amounts depend on the date of invoice preparation and registration
3. Court Decision: Partially satisfy cassation complaints, cancel the appellate court’s decision in certain parts, and refer the case for a new review.
Key Thesis: The court seeks to ensure a fair approach to taxpayers under martial law and quarantine restrictions.
