Фото: Procedure for appealing against tax notices

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Yasinskiy Yevhen

Head of tax law practice

An expert in the practice of tax law, specializes in the protection of rights in court, corporate law.

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Procedure for appealing against tax notices

Reading time: 4 min.

A tax assessment notice is a written notification from the State Tax Service that a taxpayer must pay a certain amount of a monetary obligation. In many cases, the tax authorities formulate a tax assessment notice based on the results of an audit. This happens later after they have drawn up the act. We offer you to learn more about the common types of audits, their grounds and the procedure for appealing against tax authorities' decisions.

Types of tax audits

Одним з найбільш поширених типів податкових перевірок є фактичні. Їх проводять за тим місцем, де платник податків веде свою фактичну господарську діяльність. Наприклад, це може бути магазин, офіс чи МАФ. Предметом перевірки є питання обігу готівки, наявність ліцензій, ведення касових операцій, дотримання норм трудового права. Фактичні перевірки проводяться на підставі рішення керівника контролюючого органу. Це рішення має бути оформлене у відповідний наказ. Платнику податків повинні вручити його копію. Аби провести фактичну перевірку, платника податків не зобов’язані попереджати.


It is also worthwhile to elaborate on such issues as documentary unscheduled inspections. The grounds for such an inspection include:

  1. information is received by the supervisory authority that the taxpayer violates currency or tax laws;
  2. Failure to file a tax return within the statutory period;
  3. submission to the State Tax Service of a clarifying calculation;
  4. detection of inaccurate data in tax returns;
  5. submitting an objection to the tax audit report to the State Tax Service.

According to statistics, in the period from 2017 to 2021 alone, 74% of tax audits resulted in the issuance of an act. The tax authorities draw up such a document in cases where they record violations. Over the next 2 years, the rate of audits resulting in an act increased to 85%. One might assume that businesses are really violating tax laws on a massive scale, but in practice, things are different, and the actions and opinions of tax officials regarding violations are often unreasonable. This is evidenced by the fact that in about 87% of cases where the actions of the State Tax Service are challenged, the decision is fully or at least partially in favor of the taxpayers.


How can we be of service?

Tax law is one of the areas of jurisprudence that are in the focus of the practice of Prikhodko & Partners Law Firm. When we work with clients on such requests, we can provide the following services:

  • Consulting. High-quality advice allows you to get answers to your questions without having to search for the information you need among the large amount of data in the legislation.
  • Preparation of a limited liability company for an audit and support during the audit. This helps to minimize the risk of violations by the tax authorities.
  • Appealing against the tax assessment notice and audit results. We have a good command of both the administrative method of appeal (the law provides for 10 working days from the date of receipt of the tax notice-decision to file a complaint with the State Tax Service) and are able to represent our clients' interests in court.

The team of our law firm will help you professionally. We regularly deal with cases in the field of tax law, so we are well versed in them. Fill out the form on the website and entrust the tax and legal aspects to our specialists.

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Head of tax law practice

An expert in the practice of tax law, specializes in the protection of rights in court, corporate law.

Contact now
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