- For VAT decrease adjustment notes (negative RKs) issued to a buyer-VAT payer, the filing deadline is counted from the date the buyer receives the RK, not the date it was issued: 15 calendar days in normal times, or 18 calendar days during martial law and for six months after it ends.
- The State Tax Service says the key issue is proving the date of receipt, since the Tax Code does not set a separate mechanism for confirming when a negative RK was received. It recommends using SWinED-based records; M.E.Doc data is not treated as conclusive proof by the tax authorities.
- The Supreme Court has taken a more taxpayer-friendly approach, emphasizing that the receipt date must be established before claiming lateness and that the issue cannot be reduced to comparing only the issuance date and registration date. In the example discussed, if the RK was actually received on 1 December and registered on 2 December, there is no delay.
Source: news.dtkt.ua
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
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