What we do: analyze the inspection report/certificate and tax assessment notice, calculate procedural deadlines, prepare an action plan: pay/file an administrative appeal/go to court. Result: a memo with risks, deadlines, and an algorithm (including when the obligation will become “agreed”).
Tax debt and liability
solvedIf I received a tax notice-decision stating that I have a tax debt, but did not pay it within 10 business days, can I avoid forced collection of the debt if I challenge it in court?
30.09.2025 21:00
Answers
Lorina FedanIf, after an audit, the tax authority assesses additional tax liabilities and the taxpayer does not appeal this decision, this amount becomes agreed upon 10 business days after receiving the tax assessment notice. The amounts of agreed tax liabilities are automatically entered into the taxpayer's registration card. If discrepancies arise, the taxpayer has the right to initiate a reconciliation of reporting data with the information in the DPS databases or to appeal the decision of the tax authority. Until the appeal period expires, the DPS does not collect the amounts of tax liabilities. If the taxpayer files a lawsuit in court, the tax liability remains unagreed until the court decision comes into legal force. However, the mere fact of filing a lawsuit is not a basis for removing the amount from the tax debt. To do this, it is necessary to obtain a court ruling on the opening of proceedings (Art. 171 of the Code of Administrative Procedure of Ukraine).
10.11.2025 11:01
Legal Services
What we do: prepare a statement on reconciliation of data between reporting and State Tax Service databases, communicate with the inspection, accompany adjustments to the taxpayer's account card. Result: reconciliation protocol/act + confirmation of correction of discrepancies (if any).
What we do: prepare and file a complaint against the tax assessment notice within the established time frame; compile evidence and represent your interests during the proceedings. Important: until the deadline for appeal expires, the State Tax Service does not collect the amount—we monitor this regime. Result: complaint package + support until the State Tax Service's decision (cancellation/change of the tax assessment notice or confirmation).
What we do: we prepare a claim to the administrative court, file it in accordance with Article 171 of the Code of Administrative Procedure of Ukraine, promptly obtain a ruling to open proceedings; we file a motion/secure evidence if necessary. Important: it is the ruling to open proceedings that is the basis for removing the amount from the debt; simply filing a lawsuit is not enough. Result: lawsuit accepted by the court + ruling to open proceedings; further procedural support.
What we do: monitor approval/appeal deadlines, prepare statements/petitions to prevent enforcement during the appeal process; model cash flows (partial payment, restructuring), support communication with the State Tax Service and the State Treasury Service. Result: anti-crisis action plan, correspondence with authorities, payment schedule with debt risk minimization.