Export tax invoices -not issued to a buyer, not registered

Pursuant to par. 201.10 of the Tax Code of Ukraine a tax invoice is issued, upon request of the buyer,  by a taxpayer supplying goods/rendering services to serve as a prove of the tax credit, the National Fiscal Service explains.

If supplying goods or providing services, the taxpayer, seller of goods or services, is liable to issue a tax invoice to be recorded in the relevant registry.

Par. 4 of the procedure detailing the grounds for making records in the uniform registry of tax invoices, set out in the resolution of the Cabinet of Ministers of Ukraine adopted on 29.12.2010, registered under No.1246, says that the tax invoices not issued to a buyer and kept by a seller are not subject to registration.

In particular, par. 10 and 11 of the procedure for filling out a tax invoice, set out in the resolution of the Ministry of Revenue & Duties of Ukraine passed on 14.01.2014, under No.10, says:

-                              in case of supply of goods/services to a buyer, not registered as a VAT payer, including supply and export, provisional TIN “400000000000” is reflected in “taxpayer identification number” line;

-                              the said tax invoice is kept by a person that has drawn it up;

-                              the top left side of the said tax invoice is marked by “Х” and states the reason: “07 – exports”.

Given the said above, tax invoices drawn up for export of goods, should be neither issued to a buyer, nor recorded in the registry irrespective of which goods were exported – domestically made or imported.