Challenging tax assessment notices

A tax assessment notice is the document by which the tax authority fixes the amount of a monetary liability. The deadlines for responding are short, and missing them makes the assessment agreed and opens the way to enforcement.

When to get in touch

• an assessment notice with additional charges has been issued following an audit
• you disagree with the amount, or with the finding of a breach at all
• enforcement needs to be held off while the dispute runs
• the deadline for challenging it expires within days

What the lawyer does

• analyses the assessment notice and the audit report and assesses the prospects of a challenge
• prepares the complaint to the higher-level tax authority within the 10-working-day deadline
• handles the complaint procedure and files further explanations and documents
• keeps the liability in “not agreed” status while the challenge is pending
• prepares an administrative claim within the applicable court deadlines
• represents the taxpayer before the courts at every level

Legal basis

Tax assessment notices are provided for by Article 58 of the Tax Code of Ukraine. Administrative challenge: the complaint is filed with the higher-level tax authority within 10 working days (paragraph 56.3 of the Code); it is considered within 20 calendar days, extendable to 60 calendar days (paragraphs 56.8 and 56.9); a complaint filed in time suspends performance of the monetary liability, which is treated as not agreed (paragraph 56.15). On an application to court the liability remains not agreed until the judgment takes effect (paragraph 56.18); after the administrative challenge is completed the claim is filed within one month (paragraph 56.19). An agreed amount must be paid within 10 working days (paragraph 57.3). Limitation periods are set by Article 102 of the Code.

Tax legislation and case law change frequently, and some provisions apply only for the period of martial law. This page reflects the position as of August 2026.

Frequently asked questions

Do I have to pay while the challenge is pending?

No. Where the complaint or the claim is filed in time, the liability is treated as not agreed until the procedure is complete (paragraphs 56.15 and 56.18 of the Tax Code).

How long do I have to go to court?

On the current position of the Grand Chamber of the Supreme Court (judgment of 16 July 2025 in case No. 500/2276/24), a one-month period applies after an administrative challenge and the general six-month period under the Code of Administrative Procedure applies without one; the 1,095 days in Article 102 of the Tax Code is a limitation period, not a deadline for filing a claim.

Need legal assistance? Call us or leave a request — a lawyer will contact you and explain what to do in your situation.