ADMINISTRATIVE APPEAL OF DECISIONS REGARDING THE LATE REGISTRATION OF TAX INVOICES/COLLECTIONS OF ADJUSTMENTS IN THE UNIFIED REGISTER DURING THE PERIOD OF MARITAL STATE

Introduction. The article is devoted to the study of the problem of predictability, stability of legal regulation, provision of impartial, complete and fair administrative appeal of tax notices-decisions (hereinafter — TND). In order to ensure the rights and obligations of taxpayers during the period of martial law, the legislator adopted a number of amendments to the Tax Code of Ukraine (hereinafter referred to as the Tax Code of Ukraine). Yes, from March 1, 2022 to April 1, 2024. 34 changes were made to the PC of Ukraine. Along with the changes introduced during the period of martial law, the specifics of taxation continued to apply in connection with the implementation of quarantine on the territory of Ukraine, established by the Cabinet of Ministers of Ukraine with the aim of preventing the spread of the coronavirus disease (COVID-19) on the territory of Ukraine. In connection with the introduction of martial law in Ukraine, the legislator had to promptly respond to the improvement of the norms of the Code of Ukraine, which regulated, in particular, the duty of the taxpayer to register tax invoices/adjustment calculations (hereinafter — TB/AC) in the Unified Register of Tax Invoices ((hereinafter — SRTI), application of fines for their late registration. Such circumstances led to collisions of legal norms, the difficulty of taking into account the revisions of the PC of Ukraine that were in effect in a certain period, the peculiarities of registration of TB/AC in the National Register of Taxpayers by different categories of taxpayers, which led to the issuing by the controlling body of illegal TND. Purpose. The purpose of the article is to analyze the specifics of exemption from responsibility for untimely registration in the National Register of Citizens of the Russian Federation of TB/AC drawn up from March 1, 2020 to January 31, 2022 and from February 1 to May 31, 2022, which were not registered in the National Register of Citizens in connection with due to the effect of the moratorium on the application of fines for untimely registration of TB/AC during the period of quarantine and martial law and the effectiveness of the procedure of the administrative order of appeal of the PPR with the participation of the Business Ombudsman Council (hereinafter — BOC). Materials and methods. The materials of the research are the regulatory and legal provision regarding the features of registration in the in the SRTI of TB/AC, which were not registered in the SRTI in connection with the moratorium on the application of fines for untimely registration of the TB/AC during the period of quarantine and martial law and exemption from liability for untimely registration of such TB/AC; regulation of the possibility for taxpayers to be involved in the administrative appeal procedure of the TND of the BOC. In the process of carrying out the research, the following scientific methods were used: formal-dogmatic, dialectical and system analysis methods.