17.01.2023

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Law No. 2260-IX "On Amendments to the Tax Code of Ukraine and other laws of Ukraine on the specifics of administration of taxes, fees and social security tax during martial law period and state of emergency" (formerly known as the draft law No. 7360 ") was adopted on May 12, 2022 and became effective on May 27, 2022.

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This Law provides for the renewal of, in particular, but not limited to:

(i)              Desk audits (in full) and some documentary audits, and

(ii)             VAT refund.

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1. Tax audits

• The following audits are resumed:

  • desk audits in full,

  • documentary unscheduled audits:

    • at the request of the taxpayer, and/or

    • in connection with the procedure of reorganization, termination of a legal entity or entrepreneurial activities of the private entrepreneur, liquidation of a permanent establishment or a separate division of a legal entity, initiation of bankruptcy proceedings or filing an application for de-registration of a taxpayer, and/or

    • regarding legality of VAT refund and/or negative VAT value amounting to more than UAH 100,000, and/or

    • in relation to taxpayers that were alleged of violation of currency legislation in terms of compliance with the deadlines for the receipt of goods from import operations and/or foreign currency from export operations;

• Desk audits of VAT tax returns and adjustments to VAT tax returns for reporting tax periods:​

  • February, March, April, May of 2022 – start on 21 July 2022 and end no later than 20 September 2022,

  • June, July 2022 – start on August 21, 2022 and end no later than on October 20, 2022.
    Submitted adjustments to VAT tax returns for reporting tax periods up to February 2022 shall be verified within the period specified for the reporting period on which the date of submission of such adjustment to VAT tax returns falls;

• Documentary unscheduled audits shall be executed provided the following conditions can be met:​

  • safe access to territories, premises and other property used for business activities and/or objects of taxation, or are used to generate income (profit), or related to other objects of taxation by such taxpayers,

  • safe access to documents, certificates of financial and economic activities, income received, expenses of taxpayers and other information related to the calculation and payment of taxes, fees, payments, compliance with the requirements of the law, the control over which is entrusted to tax authorities, as well as financial and statistical reporting,

  • conducting an inventory of fixed assets, inventory items, funds, withdrawing inventory balances, cash.

Documentary unscheduled audits that were started and not completed before February 24, 2022, resume and end within 60 days from the day following the day the Law became effective. Such audits shall last for the unused period.

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Documentary unscheduled audits of tax returns or adjustments to tax returns (if they are submitted), to which VAT refund application was enclosed, shall start following the effective date of the Law and last within 60 calendar days following the deadline for conducting desk audit of the relevant tax return or adjustment to such tax return.

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2. VAT refund:

• Law renews VAT refund;

• VAT refund shall be executed according to the general procedure as per the TCU provided amended time periods of the relevant desk and documentary tax audits are used;

• Approved amounts of VAT refund shall be paid back in chronological order as per the order of their entry in the Register of VAT Refund Applications;

• Amounts of VAT accrued as VAT credit during purchase of goods that were later destroyed (lost) as a result of force majeure circumstances during the period of martial law shall not be subject to VAT refund but be used as VAT credit during next reporting (tax) period until full use.

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3. Othet provisions:

• Taxpayers are no more allowed to file tax returns and other documents in writing to tax authorities during the period of martial law, state of emergency;

• The right of VAT payers to accrue VAT credit on the basis of primary accounting documents without registration of VAT invoices and / or adjustments to VAT invoices is possible only for the following tax periods: February, March, April, May of 2022;

• VAT payers temporarily, until the termination or cancellation of martial law, do not have the right to submit adjustments to tax returns (submitted to correct self-identified errors in tax returns) for the reporting (tax) periods until February 2022 in order to reduce tax obligations and/or declare VAT refund.

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The Law No. 2325-IX "On amendments to the Tax Code of Ukraine and other laws of Ukraine on reconsideration of the specific tax benefits" (formerly known as the draft law No. 7418) (the Law) was adopted on June 21, 2022 and became effective on July 1, 2022.

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The Law, in particular, terminated a number of tax benefits introduced earlier for the period of the martial law in Ukraine as a result of the adoption of the Law No. 2142-IX dated March 24, 2022, regarding taxation of imports into Ukraine of goods, including vehicles. With the entry into force of the Law:

• The business entities dealing with the import of vehicles to Ukraine cannot be registered as taxpayers of the unified tax of the third group at the rate of 2% of the income.

• Exemption from VAT of transactions involving the import of goods into the customs territory of Ukraine by the unified tax taxpayers of the first, second and third groups (including at the rate of 2%) has been canceled.

• Exemption from import duty of goods imported (forwarded) to the customs territory of Ukraine by enterprises for free circulation has been canceled.

• Exemption from VAT and excise tax on import transactions by natural persons into the customs territory of Ukraine of vehicles, as well as exemption from import duty on vehicles, have been canceled.

• The measures introduced for the purpose of simplified and accelerated customs clearance of goods have been canceled, namely: the possibility for the unified tax taxpayers of the first, second and third groups to declare the imported goods by submitting a preliminary customs declaration, as well as the provision on carrying out customs clearance of the relevant goods within no more than one working hour from the moment of presentation of goods, vehicles, customs declaration or a document that replaces it.

• Temporary rules regarding customs clearance and first state registration in Ukraine of passenger vehicles intended for the transportation of 10 or more people, cargo vehicles and special purpose vehicles, established by the Law of Ukraine dated July 6, 2005 No. 2739-IV "On certain issues of import into the customs territory of Ukraine and carrying out the first state registration of vehicles", specifically their compliance with environmental standards not lower than the "EURO-3" standard, import by legal entities for their own use and the impossibility of disposal within 1095 days from the day of the first state registration, shall not be applicable to certain types of vehicles (for example, passenger vehicles driven only by an electric engine).

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The Law No. 2308-IX "On amendments to the Tax Code of Ukraine regarding the peculiarities of taxation with a military charge on the financial support of military personnel and other persons who take direct part in hostilities under martial law" (formerly known as the draft law No. 7432) (the Law) was adopted on June 19, 2022 and became effective on July 9, 2022.

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The specified Law exempts for the period of martial law in Ukraine from taxation by military levy the income of law enforcement officers, military personnel and employees of the Armed Forces of Ukraine, the National Guard of Ukraine, the Security Service of Ukraine, the Foreign Intelligence Service of Ukraine, the State Border Guard Service of Ukraine, the privates and senior staff, servicemen, employees of the Ministry of Internal Affairs of Ukraine, some other paramilitary units, as well as other persons for the period of their direct participation in ensuring national security and defense, repel and deter the armed aggression of the Russian Federation.

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The Laws No. 2331-IX "On amendments to the Article 287 of the Customs Code of Ukraine regarding creation of facilitating conditions for functioning of industrial parks in Ukraine" (formerly known as the draft law No. 5689) and No. 2330-IX “On amendments to the Tax Code of Ukraine regarding creation of facilitating conditions for functioning of industrial parks in Ukraine” (formerly known as the draft law No. 5688) (collectively the Laws) were adopted on June 21, 2022, and became effective, respectively, on July 1 and 19, 2022.

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These Laws introduce the following amendments:

1. Corporate income tax:

• The income of a participant of an industrial park (included in the Register of Industrial Parks) is exempt from taxation subject to its being sourced from carrying out business activities exclusively on the territory (within the boundaries) of the industrial park in the following areas:

  • processing industry (for example, production of food products, soft drinks, mineral waters, textile production, woodworking, production of chemical and pharmaceutical products, metallurgical production, production of computers, electronic and optical products, etc.),

  • collection, processing and removal of waste, recovery of materials (except for waste disposal), and

  • research activities.

• The exemption is applied starting from the first day of the first month of the calendar quarter determined by the taxpayer – the participant of the industrial park – in the statement, made in an arbitrary form and submitted to the supervisory authority at the place of registration of the taxpayer, on realization of the right to apply the specified exemption, but not before the date of submission of such statement.
  The statement shall be submitted electronically through the taxpayer's electronic cabinet. Herewith, the "tacit consent" principle is applied – if the supervisory authority does not reject the exemption within 10 working days from the date of receipt of the statement, it shall be considered as accepted.​

• The exemption applies subject to the condition that the participant of the industrial park has the status of such a participant for at least 10 years and during these 10 years it:

  • carries out business activity exclusively on the territory and within the boundaries of the industrial park, and

  • does not accrue and does not pay dividends (and equivalent payments) in favor of its shareholders.
    In order to confirm the status of an industrial park participant, the data from the Register of Industrial Parks shall be used.

• The legal entities – participants of an industrial park – are not entitled to the exemption from taxation, if there is a share in their authorized capital which:​

  • is directly or indirectly owned by legal entities dealing with gambling, as well as legal entities that directly or indirectly own a share in the authorized capital of legal entities dealing with gambling;

  • is directly or indirectly owned by legal entities incorporated in the states (the territories) included by the Cabinet of Ministers of Ukraine on the offshore zones list; or

  • is directly or indirectly owned by legal entities incorporated according to the legislation of the states included by the Financial Action Task Force (FATF) on the list of states that do not cooperate in money laundering prevention.

• The amount of funds released as a result of the income tax exemption shall be directed to the development of business activities of the industrial park participant in such industrial park no later than December 31 of the following calendar year (the respective procedure for the use of the released funds by the industrial park participant must be approved by the Cabinet of Ministers of Ukraine). In the tax declaration on the corporate income tax for the tax (reporting) year, the taxpayer must indicate information about the use or non-use of the amount of funds released from taxation in full.​

• In case the participant of the industrial park does not use the funds exempted from taxation for the development of his business activities in the industrial park by December 31 of the calendar year following the tax (reporting) year, the taxpayer loses the right to exemption from taxation from January 1 of the year which follows the year when the specified funds had to be used.
  Herewith, for all other previous tax (reporting) periods of applying of tax exemption, for which the taxpayer did not use the released funds within the prescribed period and before losing the right to exemption from taxation, the taxpayer is obliged to submit an updated corporate income tax return, accrue and pay its tax liabilities for income tax, fines and penalties.

• In case of early termination of applying of the abovementioned rules on corporate income tax exemption at the taxpayer's initiative, the taxpayer is obliged to determine the income tax liability in the general manner based on the results of the tax (reporting) period when it ceased to apply the tax exemption. A similar rule applies in case the taxpayer loses the status of an industrial park participant.

• For taxpayers applying the abovementioned corporate income tax exemption, the tax (reporting) periods are the calendar quarter, half-year, three quarters and year. Herewith, the tax return shall be calculated using the cumulative total. Taxpayers cannot use only the annual tax (reporting) period.

• The exemption from taxation is not applicable to the taxation of controlled operations, the taxable object wherein shall be determined using the "arm's length" principle, as well as to the taxation of the adjusted profit of a controlled foreign company (CFC) (if the participant of the industrial park is the controlling person). The mentioned transactions and the adjusted CFC profit are taxed according to the general rules established by the Tax Code of Ukraine, with the application of the basic (principal) corporate income tax rate of 18%.

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2. Exemption from import duties and value added tax (VAT) on equipment imports by industrial park participants:

• When imported into the customs territory of Ukraine, the new equipment and accessories for it, which are classified according to the UCT ZED (Ukrainian Classification of Foreign Economics Goods) codes, the list of which is provided in the Customs Code of Ukraine, and which are imported by participants of industrial parks, included in the Register of Industrial Parks, are exempted from taxation by customs duty and VAT.

• Such an exemption is granted on the condition that the specified equipment and accessories for it:

  • are new ones (no more than three years have passed from the date of manufacture to the date of import into the customs territory of Ukraine);

  • have not ever been in use;

  • are imported by participants of industrial parks exclusively for their own use on the territory (within the boundaries) of the industrial park without the right of disposal, granting for renting or leasing, or granting another right of their use to third parties under any conditions earlier than five years from the date of their import into the customs territory of Ukraine;

  • do not originate from a country recognized as the occupying state and/or the aggressor state in relation to Ukraine in accordance with the law, and/or are not imported from the territory of the occupying state (aggressor state) and/or from the occupied territory of Ukraine, defined as such in accordance with the law.

• The special condition for VAT exemption is also the importation of the above-mentioned equipment and accessories for the purpose of carrying out by the industrial parks participants of the business activities in the same areas for which exemption from corporate income tax is applicable, as specified in section 1 above.

• The procedure for import and intended using of the abovementioned goods is to be approved by the Cabinet of Ministers of Ukraine.

• Breaching of the abovementioned conditions, as well as the loss of the status of a participant of the industrial park, entails the obligation to pay VAT, import duty and penalty in the terms and under the procedures established by the Tax and Customs Codes of Ukraine. The statute of limitations established by the Tax Code of Ukraine shall not apply herewith.

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3. Exemption from VAT for Diia City residents:

• Supply by residents of Diia City (by means of providing access to public educational, scientific and informational resources on the Internet, including via providing access to virtual classes and educational resources) of the following services are exempt from VAT:

  • educational services in the field of information technologies, including services for the provision of higher, professional higher and vocational education in such specialties as computer science, information systems and technologies, computer engineering, cyber security, data science, and

  • services for the provision of other types of education, namely computer literacy (digital literacy) training, which includes the services regarding:

    • training in digital literacy, development, modification, testing and technical support of software, including computer games,

    • training in business analysis (for the purpose of development, modification, testing and technical support of software), construction of graphic interfaces, organization of quality control processes, system administration, project management, development of documentation (for purpose of development, modification, testing and technical support of software).

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4. Property Tax

• Municipal authorities are entitled to set incentives from real estate property (other than the land plots) tax, which shall be paid in their territory, regarding non-residential premises located within the territory of the industrial park and owned by the participants of the industrial park included in the Register of Industrial Parks.

• In addition, with regard to the land fee for land plots located within the territory of industrial parks, included in the Register of Industrial Parks, concerning which the regulatory monetary assessment has been carried out, and which are used by the initiators of creation of the industrial park, by the managing company of the industrial park and participants of industrial park, municipal authorities are entitled to:

  • establish land tax rates and lease fee in an amount lower than the established amount of land tax for a respective category of land payable within the relevant territory, and

  • grant exemptions from payment of land tax.

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The Draft Law No. 7406 “On amendments to the Tax Code of Ukraine and the Law of Ukraine “On collection and accounting of the mandatory state social insurance unified contribution” regarding support of employers and employees during the martial law regime” (the Draft Law) was registered at the Verkhovna Rada of Ukraine on May 25, 2022.

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The specified Draft Law has not been considered by the Verkhovna Rada yet and is currently being worked out in its committees.

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The Draft Law proposes to introduce for the period of the martial law in Ukraine the new tax rates of:

• the personal income tax (PIT) regarding the income accrued (paid, provided) to the taxpayer in the form of wages (including principal and additional wages and other incentive and compensation payments, including those that have been made in kind) related to the labor relations, and

• the mandatory state social insurance unified contribution (the Contribution) for employers for the amount of wages accrued for each insured person per calendar month (including principal and additional wages and other incentive and compensation payments, including those that have been made in kind).
  
  The Draft Law proposes the following PIT and the Contribution rates:

  •  PIT:​

    • (A)           9% - if the taxpayer's income received from one employer does not exceed five statutory minimum wages per calendar month,

    • (B)           18% - if the taxpayer's income received from one employer exceeds five statutory minimum wages per calendar month, but does not exceed ten statutory minimum wages. The tax amount under the specified tax rate shall be calculated specifically based on the amount of such excess, and

    • (C)           25% - if the taxpayer's income from one employer exceeds ten statutory minimum wages per calendar month. The tax amount under the specified tax rate shall be calculated specifically based on the amount of excess over the tax base, in respect of which 18% PIT tax rate, as specified in para. B above, shall be applied;

  • the Contribution:​

    • 11%, but not less than the amount of the minimum insurance contribution – if the amount of wages does not exceed five statutory minimum wages per calendar month,

    • 22% - if the amount of wages exceeds five statutory minimum wages per calendar month, but does not exceed ten statutory minimum wages. The Contribution amount under the specified tax rate shall be calculated specifically based on the amount of such excess, and

    • 29% - if the amount of wages exceeds ten statutory minimum wages per calendar month. The Contribution amount under the specified rate shall be calculated specifically based on the amount of excess over the Contribution base, in respect of which 22% Contribution rate, as specified in para. B above, shall be applied.

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The Law No. 2719-IX "On Amendments to the Tax Code of Ukraine And Certain Other Laws of Ukraine Regarding Privatization of State And Municipal Property In Tax Lien, And Ensuring Administration of the Tax Debt Settlement" was adopted on 3 November 2022 and came into force on 25 November 2022

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The Law introduced the following amendments:

• granting the purchaser all rights and entrusting him with all obligations to settle the tax debt of a state or municipal enterprise upon the acquisition by the purchaser of a unified (integrated) property complex of such an enterprise as part of privatization process. Provided that the tax debt is settled in full and no later than six calendar months from the date of transfer of ownership title on the property, fines and penalties shall not be accrued on the settled amount of the tax debt, and those already accrued shall be subject to cancellation;

• absence of need to obtain the consent of the supervisory authorities for disposal in the process of privatization of a unified (integrated) property complex of a state or municipal enterprise being in a tax lien, if under the terms of the relevant sale-purchase agreement the purchaser is obliged no later than six calendar months from the date of transfer of ownership title on the property to settle completely the amount of the tax debt that caused the tax lien. After complete settlement of the tax debt by the purchaser, the relevant property shall be released from the tax lien;

• extension until 2028 of:

  • exemption from VAT in respect of transactions of debtors and sureties for the supply of goods for the purpose of settlement of the debtor's debt in accordance with the restructuring or sanation plan, and

  • effect of the rules specified in clause 39 of subsection 4 of chapter XX of the TCU for determining the taxpayer's pre-tax financial result due to write-off of the tax debt, cancellation or installments of the taxpayer's duties as part of implementation of restructuring or sanation plan by the supervisory authorities;

• introducing of the rules for determining pre-tax financial result of the taxpayer due to receiving, based on the Cabinet of Ministers of Ukraine decree, of Russia (and its residents) owned property, including the right of claim, as a result of its forced seizure under the law;

• renewal of the course of terms for taxpayers to provide answers to the requests of supervisory authorities on issues of taxation by legal entities or other non-residents conducting business activity through a permanent establishment in Ukraine of Ukrainian-sourced income received by non-residents, tax control over transfer pricing, tax control over non-residents and their permanent establishments, currency control in terms of compliance with established settlement deadlines for export and import of goods, as well as for the submission of reports, notifications and documents which submission is required by the rules of transfer pricing and/or controlled foreign companies rules;

• the effect of the rules on exemption from liability for failure to fulfill tax duties in connection with the martial law in Ukraine provided for in subclause 69.1 of clause 69 of subsection 10 of chapter XX of the TCU has been explicitly extended to the submission of reports, notifications and documents which submission is required by the rules of transfer pricing and/or controlled foreign companies rules;

• unscheduled documentary inspections have been resumed for some reasons, in particular, but not exclusively, with regard to the following cases / issues:

  • conducting of control over transfer pricing (including cases of detecting non-compliance of controlled transaction with the "arm's length" principle, non-submission or incorrect submission of the report on controlled transactions and/or transfer pricing documentation),

  • submission by the taxpayer of an objection to the inspection act or a complaint to the tax assessment notice made as a result of tax inspection,

  • receiving information certifying that a non-resident is conducting business activities through a permanent establishment in Ukraine without being put on the tax accounting,

  • taxation by legal entities or other non-residents carrying out business activity through a permanent establishment in Ukraine of Ukrainian-sourced income received by non-residents, as well as unscheduled documentary inspections of non-residents.

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The Laws No. 2836-IX "On Amendments to the Tax Code of Ukraine And Other Laws of Ukraine on Facilitation the Restoration of Ukrainian Energy Infrastructure" and No. 2837-IX "On Amendment to Chapter XXI “Final And Transitional Provisions” of the Customs Code of Ukraine on Facilitation the Restoration of Ukrainian Energy Infrastructure" were adopted on 13 December 2022 and came into force on 3 January 2023

 

These Laws provide, in particular, for the following:

• Exemption for the period of martial law, but not longer than until 1 May 2023, from taxation with import VAT and customs duty of importation into Ukraine under the import customs regime of goods that are of key importance for the survival of citizens and functioning of the state in the winter season during the martial law, including, but not limited to, internal combustion engines (including diesel or semi-diesel ones), equipment for water filtering or purifying, alternators, electric generators, transformers, electric batteries, Starlink satellite communication platform equipment, navigation devices, etc.
  The exemption, however, cannot be applicable to the goods originating or being imported from Russia and/or Ukrainian occupied territories.

• For the purpose of paying the environmental tax, during the period of martial law in Ukraine and within 30 days from the date of its termination or cancellation, electric generators shall not be considered stationary sources of pollution. This means that business entities operating electric generators will not be considered as environmental tax taxpayers during martial law.

• During the period of martial law and within 30 days from the date of its termination or cancellation, business entities operating electric generators are allowed to store up to 2,000.00 liters of fuel for refueling the generator at each facility where such generators are located without receiving any permission documents. If a business entity plans to store more than 2,000.00 liters of fuel, it must submit a declaration to the territorial body of the State Tax Service of Ukraine on conducting fuel storage business activities.
  Herewith, facilities where fuel is stored exclusively for refueling electric generators and its total volume does not exceed 2,000.00 liters are not considered excise storages. Respectively, they do not have to meet the requirements that excise storages must meet according to the provisions of the TCU, while business entities that own such facilities shall not be subject to the obligations that the provisions of the TCU impose on managers of excise storages.

• The rules for exempting taxpayers who failed to fulfill their tax duties during the martial law regime have been updated. It has been determined that the updated rules should be applied starting from 27 May 2022, i.e. from the date when the provisions of the TCU regarding the exemption of taxpayers from liability for non-fulfilment of tax duties during the martial law generally came into force for the first time based on the then-adopted Law as of 12 May 2022 No. 2260-IX.
  Updated rules provide for exemption from liability for:

  • a taxpayer which is proved unable to fulfill its tax duties subject to the condition that the tax duties fulfillment is done within six months after the termination of martial law in Ukraine,

  • a taxpayer which is proved unable to fulfill its tax duties related to its branch, representative office, separate or other structural unit - for the period until the termination of martial law in Ukraine within the scope of activities carried out through such branches, representative offices, subdivisions,

  • a taxpayer which is proved able to perform in timely manner tax duties, but did not fulfill them - provided that such taxpayer:

    • registered in the Tax Invoices Unified Register (TIUR) tax invoices and adjustment calculations which date of execution falls within the period from 1 February to 31 May 2022 - by 15 July 2022,

    • registered in the TIUR consolidated tax invoices and/or adjustment calculations to them which date of execution falls within the period from 1 February to 31 May 2022 and which had been executed regarding transactions for which conditional VAT liabilities to be accrued - by 20 July 2022,

    • submitted reports for 2021 (the deadline for which submission falls within the period from 24 February 2022 to 1 June 2022), for the Ist quarter of 2022 and for February - May 2022 - by 20 July 2022,

    • paid taxes and levies for 2021, for the Ist quarter of 2022 and for January - May 2022 - by 1 August 2022 (except for the personal income tax and/or military levy which should have been paid by 31 December 2022),

    • paid monetary obligations imposed by the supervisory authorities which payment deadline falls within the period from 24 February 2022 to 1 June 2022 - by 1 August 2022.
      Provided that the tax duties are fulfilled within the specified time frames and, respectively, the taxpayer is exempt from liability, tax assessment notices that imposed fines and/or penalties on a taxpayer for the late fulfillment of tax duties shall be deemed to be canceled from January 3, 2023,

  • a taxpayer, including with regard to its branch, representative office, separate or other structural unit, which delayed fulfillment of the tax duties which fulfillment deadline fell within the period starting from 24 February 2022 until the day of renewal of possibility of the fulfillment, even despite the renewal of possibility to fulfill the specified tax duties - subject to the condition that the specified tax duties are fulfilled within 60 calendar days from the first day of the month following the month of the renewal of the taxpayer's ability to fulfill the tax duties,

  • the IIIrd group unified tax taxpayer at 2% rate of income which delayed the fulfillment of the tax duties which fulfillment deadline fell within the period starting from 24 February 2022 until the day when the specified unified tax special regime became effective - subject to fulfilling of the specified tax duties within 60 calendar days from the date of return of the taxpayer to the taxation system which was applicable to it before its changing into the unified tax special regime.

If a taxpayer, following the procedure for tax reports amending provided by the TCU, corrects on its own the mistakes which have caused understatement of the tax liability in the reporting tax periods falling within the martial law effect period, such a taxpayer shall be exempt from accrual and payment of fines and penalties.

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Procedure for confirmation of a taxpayer's possibility or impossibility to fulfill the tax duties and the list of documents for such confirmation were approved by the Ministry of Finance of Ukraine Decree dated July 29, 2022, No. 225 (came into force on September 6, 2022);

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• renewal of the course of terms for submission and consideration of complaints against decisions on rejection of tax invoices / adjustment calculations registration in the TIUR. Herewith, temporarily, for the duration of the martial law, consideration of complaints against decisions on rejection of tax invoices / adjustment calculations registration shall be conducted within 10 business days from the date of receipt of such a complaints by the State Tax Service with taking into account the principle of "tacit consent".