Yasinskiy Yevhen
Yasinskiy Yevhen

Attorney

Phone numbers
+38 (073) 007-41-00

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

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Appeal of tax notice-decision

Appeal of tax notice-decision

If, according to the results of the inspection of the entrepreneur – taxpayer – (including the inspection of the tax declaration) the control body did not find any violations, a certificate is sent, which gives the opportunity to breathe a sigh of relief. Instead, in case of detection of violations, an act is drawn up, and based on it, a tax notice-decision is adopted within 10 working days after the inspection act is handed over to the taxpayer.

The taxpayer has the right to disagree with the addition of tax liabilities, fines (financial) sanctions contained in the PPR. The legislation provides for the possibility of appealing tax notices-decisions in an administrative procedure (that is, in a higher subordinated body of the tax service) or in court – Article 56.1. 56 of the Tax Code of Ukraine.

At the same time, experienced lawyers of Prikhodko&Partners have already developed algorithms for protecting the rights of taxpayers in disputes with the State Tax Service. Do not waste time, contact us to defend your interests!

Administrative appeal procedure

To attention! The procedure for appealing the decisions of supervisory bodies (including PPR) is established by Chapter 4 of Section II of the PKU, as well as the Procedure approved by Order of the Ministry of Finance № 916 dated 10.21.2015.

A complaint regarding the requirements of the DPS body shall be submitted in writing or in electronic form, and must contain:

  • P.I.B./ name of the enterprise;
  • EDRPOU code, tax address;
  • the name of the DPS body that adopted the tax notice-decision;
  • PPR details;
  • justification for appealing the PPR;
  • reference to the relevant normative legal acts;
  • the list of attached documents.

If necessary, documents, calculations and evidence that the taxpayer deems necessary to provide are attached to the complaint.

WARNING! The deadline for submitting a complaint within the framework of an administrative appeal of the PPR is 10 working days after receiving the decision of the supervisory body.

For non-residents who are not registered as VAT payers, a separate PPR Appeal Procedure has been adopted – approved by Cabinet Resolution № 73 of February 2, 2022.

Challenging the PPR in court

You can file a lawsuit with the court immediately after receiving the PPR, or in case of rejection of the complaint requirements, to a higher subordinate body of the DPS. The procedural term for applying to the court with a claim for annulment of a tax notice-decision is:

  • in the case when the administrative appeal procedure was applied, within a month after the end of the administrative appeal procedure;
  • in the event that the taxpayer did not use the procedure of pre-trial dispute resolution, the term for filing a lawsuit in court is 1,095 days.

Importantly! In order for the taxpayer not to incur a tax debt in connection with non-payment of the PPR, it is necessary to notify the supervisory body about the application of the PPR appeal procedure. Until such an appeal is concluded, there will be no tax debt.

Calculate the cost of services

1 question

Did you file an objection to the inspection report?

Yes
No

2 question

Did you apply the administrative appeal procedure?

Yes
No

3 question

Is the amount of the tax notice-decision greater than UAH 1,240,500?

Yes
No

4 question

Have other lawyers handled your case?

Yes
No

5 question

Do you need legal assistance urgently?

Yes
No

Is it possible to get a lawyer's consultation online if it is not possible to come to the office?

Of course. We provide consultations both online and in the office. Online consultation is possible in any convenient way for the client. It can be a video call through a convenient messenger or a video conference format.

Where to complain to the tax office?

You can appeal the decision of the tax office in the district administrative court. We provide full support for tax disputes. If you need legal support that will give results – leave a request on our website.

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Tax practice

Environmental tax return Maternity payments for sole proprietors A lawyer for bloggers Attorney on transfer pricing Legal support in a case of tax evasion Lawyer for OnlyFans models Unblocking a tax invoice Submission of a declaration of property status and income Recalculation of real estate tax Preparing an enterprise for a tax audit Cancellation of registration (status) of a single tax payer Permit for emissions of pollutants into the atmosphere Declaration of income of individuals Taxation of income from OnlyFans Export of currency across the border Tax claim appeal De-risking of the enterprise Individual tax consultation Tax consultation Return of deposits from a liquidated bank License to manufacture tobacco products Appealing the act of inspection of the State Audit Service Appealing tax notification decisions Appealing the conclusion of the State Audit Service Appealing against a tax decision Declaration of currency values when crossing the border Appealing the decision on compliance with risk criteria Presentation of the VAT payer data table Violation of the rules of trade in tobacco products Violation of the rules of trade in alcoholic beverages Consultation with a tax lawyer Obtaining a license to sell alcoholic beverages Obtaining a fuel storage license Obtaining a license to sell fuel Declaring cryptocurrency for civil servants when submitting a declaration to NAZK Financial monitoring of individuals Appeal of tax notice-decision Explanation for unlocking tax invoices Certificate of origin of funds Legal support of tax audits FINANCIAL MONITORING IN UKRAINE Exclusion of an enterprise from risky Enterprise risk consulting Appealing a tax audit VAT lawyer Excise lawyer Personal income tax lawyer Unlocking tax invoices Optimization of taxation Tax lawyer VAT refund