{"id":1708,"date":"2026-05-29T03:33:23","date_gmt":"2026-05-29T00:33:23","guid":{"rendered":"https:\/\/svaroglaw.com\/dosudove-vregulyuvannya-podatkovyh-superechok\/"},"modified":"2026-09-14T17:26:25","modified_gmt":"2026-09-14T14:26:25","slug":"dosudove-vregulyuvannya-podatkovyh-superechok","status":"publish","type":"page","link":"https:\/\/svaroglaw.com\/en\/advokat-z-podatkovyh-sporiv\/dosudove-vregulyuvannya-podatkovyh-superechok\/","title":{"rendered":"Pre-litigation settlement of tax disputes"},"content":{"rendered":"

Pre-court settlement of tax disputes has a specific form in the Tax Code: an administrative appeal against a tax notice-decision to a higher tax authority. It is the only way to challenge an assessment without a fee and without a claim, and while the appeal is pending the monetary liability remains unagreed: no tax debt arises. But the procedure has a flip side that shapes the whole strategy: after the tax service refuses, you have one month to go to court instead of the six you would have had if you had gone straight there para. 56.19 of the Tax Code<\/span>; that is how the Supreme Court reads the provision in its judgment of 26 November 2020 in case No. 500\/2486\/19.<\/p>\n

So the decision to \u201ctry to settle with the tax office first\u201d should not be automatic: the choice depends on the strength of the arguments, the sum at stake and the tax service\u2019s position in similar disputes.<\/p>\n

<\/svg>+38 095 554-54-24<\/span><\/a>legal consultation<\/span><\/div>\n

How the appeal is filed<\/h2>\n
10 working days to file the appeal<\/b><\/div>
20 days for the tax service to decide<\/b><\/div>
up to 60 days if the period is extended<\/b><\/div><\/div>\n

The appeal goes to the higher tax authority (for notices issued by territorial offices, that is the State Tax Service of Ukraine) within 10 working days following the day the notice was received para. 56.3, Art. 56 of the Tax Code<\/span>. Miss it, and the right of administrative appeal is lost; only the court remains, and on a different clock. A copy of the appeal goes at the same time to the office that issued the notice para. 56.5<\/span>.<\/p>\n

The appeal is considered within 20 calendar days para. 56.8<\/span>; the head of the authority may extend that to 60 days, notifying the taxpayer in writing before the twenty-day period ends. If a reasoned decision is not sent in time, the appeal is deemed fully allowed in the taxpayer\u2019s favour and the notice cancelled para. 56.9<\/span>. We keep track of that date ourselves.<\/p>\n

The taxpayer has the right to take part in the hearing of the appeal in person: to file additional documents and to give oral explanations.<\/p>\n

\"Pre-court<\/a><\/p>\n

What the appeal gives you: an unagreed liability<\/h2>\n

While the administrative appeal is pending, the monetary liability is treated as unagreed. That means:<\/p>\n