Internal invoices are not proof: how Rivne tax authorities and court "grounded" the electronics store chain "YABKO"

Internal invoices are not proof: how Rivne tax authorities and court "grounded" the electronics store chain "YABKO"

While the beneficiaries of «YABKO» are running around the media and trying to place their «mooing rebuttal» regarding the blow from the BES at a bargain price, the tax authority continues to systematically win in courts against this hub of contraband trade.

Here is a fresh court decision that clearly states that LLC «Specialtech», under which «YABKO» operates, does not have documents for the goods it sells and is trying to hide behind commission agreements with individual entrepreneurs (IPs).

The court merely laughed at this and confirmed a fine of nearly 800 thousand hryvnias. And this is just for one store in Rivne.

On February 11, 2026, the Lviv Regional Administrative Court fully denied LLC «SPECIALTECH», which conducts business under the brand of the electronics store chain «Yabko», in canceling several tax fines.

The total amount of penalties for selling equipment without documents proving its origin amounted to over 760 thousand hryvnias.

The respective decisions were made by Judge Andriy Hulyk in 4 cases *(No. 380/3655/25, No. 380/5739/25, No. 380/4288/25, No. 380/11988/25)*.

At the end of 2024, employees of the Main Directorate of the State Tax Service in Rivne region conducted a series of actual inspections in «Yabko» stores in the city of Rivne (including on Soborna Street and in the «Equator» shopping center).

During the inspections, inspectors discovered technically complex household goods (smartphones, mobile phones, headphones, vacuum cleaners, etc.) on display, for which the sellers could not provide any primary documents confirming their origin and proper accounting.

Based on the results of these inspections, the Lviv tax authority (since the company is registered in Lviv) issued tax notification-decisions (TNDs) imposing fines on LLC «SPECIALTECH» in the amounts of:
• 150,457 UAH;
• 182,462 UAH;
• 75,770 UAH (and additionally 2,040 UAH);
• 357,853 UAH.

Position of the «Yabko» company (LLC «SPECIALTECH»)

Disagreeing with the fines, the company’s lawyers appealed to the court. They justified their position by claiming that the inspectors allegedly did not take into account the documents provided by them.

In particular, representatives of the chain argued that the goods were transferred to retail points from their main warehouse, providing «internal transfer invoices», and in one of the cases, they referred to a commission agreement with an individual entrepreneur. The company insisted that these internal documents were sufficient for accounting at a specific retail point.

What the court decided

The court thoroughly reviewed the materials of the four cases and sided with the State Tax Service.

The main conclusions of the court are as follows:

• Internal invoices are not proof of origin. The court ruled that an internal transfer invoice (from warehouse to store), created by the company itself, does not allow identifying the real supplier of the goods. In other words, it does not explain where and from whom LLC «SPECIALTECH» initially purchased these smartphones.
• Documents must be available at the point of sale. According to the law on cash registers (RRO), business entities are obliged to provide documents for the goods at the start of an inspection directly at the store. Providing expenditure invoices or commission agreements after the inspection (during the appeal of the act or in court) does not exempt the company from a fine for their absence at the time of the inspectors’ visit.
• «Gray» goods. Since there were no documents for the equipment in the stores at the start of the inspection, the tax authority rightfully classified this as the sale of unaccounted goods.

Taking this into account, the court concluded that the tax service acted within the law and denied LLC «SPECIALTECH» in satisfying its claims in full.