Tax law

The firm’s tax practice covers dealings with the tax authorities at every stage: from the audit and the objections to the audit report through to litigation and defence in criminal proceedings about tax. We act for companies, sole traders and individuals.

A tax lawyer in Kyiv assists during an audit, after the audit report is received, in the administrative appeal of decisions, in court and in criminal proceedings concerning tax. Meetings are held at our office or online.

Our services

• Challenging tax assessment notices – a complaint to the higher-level authority or a claim in court
• Support during tax audits – admission of the auditors, the limits and duration of the audit, objections to the report
• Tax disputes in court – proving that transactions were genuine, at all instances
• Unblocking VAT invoices suspended in the register – explanations and documents, complaints, risky-taxpayer status
• Defence in tax evasion cases – Article 212 of the Criminal Code, coordinated with the tax dispute
• Taxation of income from OnlyFans – legal characterisation of payments, choice of tax model

When to see a tax lawyer

• you have received an audit order or a request to provide information and documents
• you have received an audit report with additional assessments – there are 10 working days to file objections
• you have received a tax assessment notice and disagree with the amount
• registration of a VAT invoice has been suspended or the company has been classed as risky
• the audit materials have been passed to the Economic Security Bureau or criminal proceedings have been opened

How we handle these matters

• we count the deadlines from day one – in tax disputes they run in days, not months
• we combine the tax and the criminal lines of defence where Article 212 of the Criminal Code is in play
• we build the evidence for transactions in advance, not after the audit report lands
• the scope of work and the payment terms are agreed in writing before we start

How the work proceeds

1. First conversation: we establish what stage the matter has reached and which deadlines are already running.
2. Review of documents: the audit report, decisions, primary documents, correspondence with the tax authority.
3. Position and documents: objections, a complaint, explanations or a claim – within the deadline.
4. Support through to the outcome: consideration of the complaint, court and, where needed, defence in criminal proceedings.

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 October 2026.

Frequently asked questions

How long do I have to challenge a tax assessment notice (tax notification-decision)?

A complaint to the higher-level tax authority is filed within 10 working days following the day the tax assessment notice is received (paragraph 56.3 of the Tax Code). If an administrative appeal was pursued, a claim can be filed in court within one month following the day the appeal procedure ended (paragraph 56.19 of the Tax Code).

Do I have to pay the additional assessment while the challenge is pending?

No. A complaint filed in time suspends performance of the monetary liability until the administrative appeal procedure is complete, and the amount challenged is treated as not agreed (paragraph 56.15 of the Tax Code). During a court challenge, the liability is treated as not agreed until the day the judgment takes legal effect (paragraph 56.18 of the Tax Code).

What should I do if I receive an audit report?

If you disagree with its conclusions, file objections, additional documents and explanations with the tax authority that carried out the audit within 10 working days from the day following receipt of the report (paragraph 86.7 of the Tax Code; the exception is an unscheduled audit under subparagraph 78.1.5). These materials become an integral part of the audit materials.

What should I do if registration of a VAT invoice has been suspended?

The procedure and grounds for suspension are set by the Cabinet of Ministers of Ukraine (paragraph 201.16 of the Tax Code). Written explanations and copies of documents can be submitted to the tax authority within 365 calendar days following the date the tax invoice was drawn up (paragraph 6 of the Procedure approved by Order of the Ministry of Finance No. 520 of 12 December 2019).

When can a tax case become a criminal one?

Liability under Article 212 of the Criminal Code arises for wilful evasion of taxes that has resulted in the actual non-receipt of a substantial amount of funds by the budget – an amount that equals or exceeds 3,000 tax-free minimum incomes (note to Article 212 of the Criminal Code). For criminal offences, the tax-free minimum income equals the tax social benefit – 50% of the subsistence minimum for an able-bodied person as of 1 January (paragraph 5 of subsection 1 of Section XX and subparagraph 169.1.1 of the Tax Code): in 2026 it is UAH 1,664, so a substantial amount starts at UAH 4,992,000. The law provides for release from criminal liability if, before the person is prosecuted, the taxes have been paid and the damage caused to the state by their late payment has been compensated (part 4 of Article 212 of the Criminal Code), but not in every case.

Need legal assistance in a tax matter? Call us or leave a request – a lawyer will contact you and explain what to do next.