{"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":"2026-07-14T10:11:40","modified_gmt":"2026-07-14T07:11:40","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":"

An administrative appeal against a tax assessment notice is the only way to challenge additional tax charges; it costs nothing and immediately halts the accrual of tax debt. But there is a catch that most advisory services fail to mention: once the State Tax Service has rejected your claim, you have only one month left to take the case to court<\/strong> \u2014 instead of the six months you would have had if you\u2019d gone to court straight away.<\/p>\n

Therefore, the decision to \u2018try to reach an agreement with the tax authorities first\u2019 should not be automatic. Sometimes a pre-court appeal is the right first step; sometimes it is better to go straight to court. The right choice depends on the strength of your arguments and on how uncompromising the position of the higher-level tax authority is.<\/p>\n

+38 095 554-54-24<\/a> \u2014 legal advice<\/strong><\/p>\n

How to lodge a complaint<\/h2>\n

The appeal must be lodged with the higher-level supervisory authority<\/strong> within 10 working days<\/strong> from the day following receipt of the tax assessment notice (paragraph 56.3 of Article 56 of the Tax Code of Ukraine). If you miss this deadline, the right to an administrative appeal is lost; the only option remaining is court proceedings, subject to a different time limit.<\/p>\n

The appeal is considered within 20 calendar days<\/strong>; the head of the authority may extend the time limit to 60 days<\/strong> by notifying the taxpayer in writing. If a decision on the appeal is not sent on time<\/strong> \u2014 it is deemed to have been upheld in favour of the taxpayer, and the tax assessment notice is cancelled (paragraph 56.9 of the Tax Code of Ukraine). It is worth being aware of this rule and monitoring it yourself: the tax authorities are not always quick to acknowledge their own inaction.<\/p>\n

The taxpayer has the right to participate in person<\/strong> in the consideration of the appeal \u2014 to submit additional documents and provide oral explanations. It is worth exercising this right: a written appeal without the taxpayer being present is more likely to be unsuccessful.<\/p>\n

The main advantage<\/h2>\n

Whilst the administrative appeal is ongoing, the financial liability is deemed unresolved<\/strong>. This means:<\/p>\n