We advise and represent organizations that disagree with the findings of a tax audit conducted by the State Tax Service of Ukraine.
We examine the audit report and audit materials, prepare well-grounded objections backed by evidence and defend your position while they are reviewed. If you’ve received a tax assessment notice (podatkove povidomlennia-rishennia), we handle its appeal through the administrative procedure and in court.
Legal protection within the UHY Prostir group is provided by the Olha Petrukhina Law Firm*. The firm’s attorneys (advokaty, licensed lawyers in Ukraine) develop the defense strategy and represent the client in the dispute, while UHY Prostir tax consultants, as a separate engagement, check the additional tax assessed by the tax authority against your accounting records.
What happens after a tax audit
If the tax authority finds violations during an audit, it draws up an audit report and gives it to you. The report itself doesn’t yet require you to pay anything. At this stage, you can file objections and documents so that the tax authority considers your position before it makes a decision.
After that, the tax authority sends you a tax assessment notice. It states the amount to be paid or the changes to be made to your tax returns. It’s this decision that is appealed — to a higher-level tax authority or in court.
The procedure and deadlines for appeals are set by the Tax Code of Ukraine. We determine them for each situation under the current version of the law.
How we can assist you
- Prepare objections to a tax audit report.
- Check the tax authority’s calculations against your accounting data and support your position with documents.
- Assess whether the audit procedure was followed and how any violations affected the results.
- Present your position when the objections are reviewed.
- Appeal a tax assessment notice to a higher-level tax authority or in court.
Our services
- Legal analysis of the audit report. We assess whether the tax authority’s findings are lawful and whether it followed the audit procedure. We identify which findings can be challenged and on what grounds.
- Objections to the audit report. We prepare objections that set out the legal position, with references to the law and court practice and the documents that support it. We file them on your behalf or hand them over to you for filing.
- Participation in the review of objections. An attorney represents the company before the tax authority when the objections are reviewed and defends its position.
- Complaint against a tax assessment notice. If the tax authority still issues a decision, we prepare a complaint to a higher-level tax authority and represent your interests while it’s reviewed.
- Appeal in court. We prepare a claim to the administrative court and represent the company in the court of first instance, on appeal and in cassation (a review of how the lower courts applied the law).
Service fees
We set the attorney’s fee individually for each case. The attorney’s fee is based on:
- the number and complexity of the disputed issues;
- the time left to prepare.
The fee is calculated separately for preparing objections, a complaint or a claim and for the attorney’s participation in the review of objections and in court hearings.
Work with documents — processing the audit report and its annexes, source documents and correspondence with the tax authority — is usually done by the attorney’s assistants. It’s paid separately: not as part of the attorney’s fee, but at a cost that depends on the volume and condition of the documents.
We prepare a proposal after reviewing the audit report or the tax assessment notice. We set out the scope of services, the attorney’s fee, the cost of work with documents and the payment terms in our proposal and record them in the relevant agreement.
A review of the calculations by UHY Prostir tax consultants is a separate engagement with a separate proposal.
Court fees, translation services, external experts and travel costs aren’t included in the attorney’s fee or in the cost of work with documents. You pay any additional costs only after we’ve agreed on them with you.
Getting started
- Tell us what you need
Submit a request or contact us. Tell us about your situation and when you received the tax audit report or the tax assessment notice. - Provide information for a proposal
We’ll clarify the details during a call and review the report or notice. This helps us define the scope of services, the attorney’s fee and the timeline. - Review our proposal
You’ll receive the scope of services, the attorney’s fee and the timeline. We’ll discuss your questions and agree on the terms. - We sign the agreement
We send you a draft agreement with the agreed terms, in Ukrainian and English if needed. You review it and return it with comments or confirmation of your approval. We agree on the final version, sign the agreement and move on to planning our cooperation.
Our process
After the agreement is signed, we provide our services in the following stages:
- We build the position
We study the audit report, the documents and the correspondence with the tax authority and discuss the arguments with you. - We prepare and file the objections
We draw up the objections with annexes and file them in the agreed way. By agreement, we take part in their review. - We assess the result
We analyze the tax authority’s decision and explain what to do next. - We appeal the decision
If the tax authority issues a tax assessment notice, we prepare, by separate agreement, a complaint to a higher-level tax authority or a claim in court and represent you.
What you can expect
Depending on the agreed task, you’ll receive:
- A legal position in the dispute with the tax authority, built by an attorney.
- Objections, a complaint or a statement of claim prepared and filed by an attorney.
- Representation by an attorney before the tax authority during the review of objections and in court.
- Protection of your interests at every stage of the dispute — from objections to cassation.
- Confidentiality of all information about your case under attorney-client privilege.
The attorney defends your position, but no outcome can be guaranteed: the decision is made by the tax authority or the court.
Why clients choose UHY Prostir
We combine our experience in Ukraine with the international experience of the UHY International network to serve Ukrainian and international clients.
- Independence, integrity and objective professional judgment.
- In business since 2003.
- A member of UHY International, a global network of specialists in audit, tax and consulting: 340 offices in 95 countries and over 10,000 professionals.
- Doing business abroad: if you already have a business in another country or plan to open and grow one, we can assist by connecting you with our UHY International office in that country, where you can discuss registration, accounting, tax and audit matters.
- Remote collaboration where the nature of the engagement allows.
- Communication and document preparation in Ukrainian and English.
* The legal services described on this page are provided by the Olha Petrukhina Law Firm. The firm is part of the UHY Prostir group and is solely responsible for the services it provides. The legal and attorney services referred to on this page are provided by the firm’s team. Calculation reviews and tax advice are provided by UHY Prostir.
