# Challenging tax audit results: from objections to court

> We advise and represent companies in disputes with the State Tax Service of Ukraine: objections to an audit report, complaints and court appeals.

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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](https://zakon.rada.gov.ua/laws/show/2755-17). 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

1. **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.
2. **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.
3. **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.
4. **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:

1. **We build the position**\
We study the audit report, the documents and the correspondence with the tax authority and discuss the arguments with you.
2. **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.
3. **We assess the result**\
We analyze the tax authority’s decision and explain what to do next.
4. **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.

## Frequently asked questions

### Can the audit report itself be appealed

No. The report records the audit findings, but it doesn’t by itself require you to pay anything. You state your disagreement with it in objections to the tax authority that conducted the audit. What is appealed is the tax assessment notice — to a higher-level tax authority or in court. [Articles 56 and 58 of the Tax Code of Ukraine](https://www.tax.gov.ua/nk/spisok2/glava-4--viznachennya-sumi-pod) set out the appeal procedure.

### How much time do you have to file objections

The deadline is set by [clause 86.7 of the Tax Code of Ukraine](https://www.tax.gov.ua/nk/spisok2/glava-8--perevirki-/) and runs from the day you received the audit report. For certain types of audits, the deadline is different. So tell us the date you received the report: we’ll check the deadline against the current version of the Code.

### What documents are needed for objections

The audit report with all annexes, proof of the date you received it, the documents ordering the audit, and requests and correspondence with the tax authority. We also need source documents, accounting registers and tax returns for the disputed transactions. We refine the list after the initial analysis.

### Who checks the tax authority’s calculations

UHY Prostir tax consultants check the tax authority’s calculations against your accounting records and tax returns as a separate engagement. The firm’s attorneys take the results of this review into account in the legal position.

### Can you object to only some of the findings

Yes. We can prepare objections only to the transactions, calculations or findings you disagree with.

### Can an attorney represent the company during the review of objections

Yes, if this is provided for in the agreement. A taxpayer can take part in the review in person or through a representative, so the attorney will present your position and give explanations. For details, see the [procedure of the State Tax Service of Ukraine](https://tax.gov.ua/data/files/573544.pdf).

### Can a tax authority decision be appealed without objections to the audit report

Yes. Not filing objections doesn’t take away your right to appeal the tax assessment notice. But objections let you present your position earlier, before a decision is made. We check the appeal deadlines under [Article 56 of the Tax Code of Ukraine](https://www.tax.gov.ua/nk/spisok2/glava-4--viznachennya-sumi-pod).

### Do you have to file a complaint with the tax authority first

No. A tax assessment notice can be appealed in court either after a complaint to a higher-level tax authority or without one. However, if the decision is already being appealed in court, a complaint about it can’t be filed with the tax authority.

### Do you have to pay the amount while the appeal is ongoing

No. While a complaint filed on time or a court case is being considered, the disputed amount is treated as not yet agreed and doesn’t have to be paid.

### Do you guarantee the decision of the tax authority or the court

No. The tax authority or the court makes the decision, so it can’t be guaranteed. The law firm is responsible for the quality of its legal assistance within the agreement and the soundness of the legal position it prepares. We explain the prospects, risks and limits of our assistance before signing the agreement.

## Insights

Practical articles on audit, accounting, HR administration, reporting, payroll, tax and legal matters.

- [Objection to a Tax Audit Report](https://www.uhy-prostir.com/en/blog-en/objection-to-a-tax-audit-report/index.html.md): A tax audit often raises concerns among business owners due to potential consequences such as additional tax assessments, fines and even administrative liability for violations of tax laws. (2024-12-30)
- [Suspended VAT Invoice Registration: Steps and Deadlines](https://www.uhy-prostir.com/en/blog-en/unblocking-a-tax-invoice-reasons-for-blocking-and-a-step-by-step-action-plan/index.html.md): Steps to resolve suspended VAT invoice registration in Ukraine: STS receipts, supporting documents, submission deadlines and appeals against refusal. (2026-07-06)
- [Cash Registers (RRO/PRRO) for Sole Proprietors in 2022: Installation Requirements, Penalties, and How to Appeal Them](https://www.uhy-prostir.com/en/blog-en/fiscal-registrars-for-individual-entrepreneurs-in-2022-installation-requirements/index.html.md): From January 1, 2022, most individual entrepreneurs are required to use fiscal registrars (RRO/PRRO). We cover the installation requirements, the fines and how to appeal them. (2022-01-27)
- [Related Audit Services](https://www.uhy-prostir.com/en/blog-en/related-audit-services/index.html.md): Every day, businesses face new challenges: changes in legislation, growing regulatory requirements and the need for financial transparency. We explain what related audit services are and when a business needs them. (2025-03-24)

## Contacts

- Email: hello@uhy-prostir.com
- Address: 14 Vasylkivska St., STEND Business Center, office 315, Kyiv
- Request a proposal: https://www.uhy-prostir.com/en/contacts/#contact-form