Tax debt and liability

30.09.2025 21:00 • Question

If 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?

1 Answers

Lorina Fedan

Answer provided 10.11.2025 11:01

If, 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).

The answer is informational and does not replace a full legal consultation. For a detailed analysis of your situation, contact a lawyer directly.