Guide · Tax
What should a foreign owner do when Ukraine's tax authority audits the company?
When Ukraine's tax authority audits a company whose owner lives abroad, the deadlines run from the day documents reach the company. The company has 10 working days to file objections to the audit report. After the tax notice-decision arrives, it has 10 working days either to pay or to file a complaint to the higher tax authority, which suspends payment. During martial law, paying the assessed tax within 30 calendar days cancels the fines. A court claim follows within one month after the complaint is decided.
Every deadline below comes from the Tax Code of Ukraine as published on the Verkhovna Rada portal, consolidated text as amended up to 17 September 2026, read on 22 October 2026.
Key Solutions prepares objections to tax audit reports and complaints against tax notice-decisions, working with documents sent from abroad.
Make sure the documents reach you
Deadlines count from receipt, so delivery decides everything. A company that files reports electronically, or has passed online identification in the taxpayer's e-cabinet, can correspond with the tax authority electronically. If it has applied to receive documents through the e-cabinet, the authority sends them there and emails a notice with the type, date and time of each document (Tax Code of Ukraine, Art. 42.4). For an owner abroad, that e-mail notice is the earliest warning that a deadline has started.
The audit step by step
| Step | Deadline | Tax Code |
|---|---|---|
| Notice of a scheduled documentary audit | Copy of the audit order and a written notice at least 10 calendar days before the audit starts | Art. 77.4 |
| Start of an on-site audit | Auditors show the audit direction and a copy of the order; both name the type, grounds, dates and period audited | Art. 81.1 |
| Objections to the audit report | 10 working days from the day after receipt of the report | Art. 86.7 |
| Review of the objections | Notice of the hearing within 2 working days, at least 4 working days before it; review within 10 working days | Arts. 86.7.1, 86.7.2 |
| Tax notice-decision without objections | Within 15 working days after the report is delivered | Art. 86.8 |
| Payment if there is no appeal | 10 working days after receipt of the tax notice-decision | Art. 57.3 |
| Complaint to the higher tax authority | 10 working days after receipt of the tax notice-decision | Art. 56.3 |
| Decision on the complaint | 20 calendar days, extendable up to 60 | Arts. 56.8, 56.9 |
| Court claim after the complaint | Within one month after the administrative appeal ends | Art. 56.19 |
Objections to the audit report
Objections go to the tax office that ran the audit, together with additional documents and explanations, including documents that show absence of fault, mitigating circumstances or grounds for release from financial liability (Art. 86.7). They become part of the audit file and are reviewed by the office's standing commission on objections.
- The office notifies the company of the date, time and format of the review within two working days of receiving the objections, and no later than four working days before the review (Art. 86.7.2).
- The company can take part in person or through a representative, including by videoconference, if it says so in the objections (Art. 86.7.3).
- The commission reviews the file within 10 working days and sends its answer to the company (Art. 86.7.1).
The complaint against a tax notice-decision
The complaint goes to the higher tax authority in writing or electronically, with copies of documents, calculations and evidence, within 10 working days after the company receives the tax notice-decision (Art. 56.3). Three rules work in the company's favour:
- Payment is suspended. A complaint filed on time suspends the obligation until the appeal ends, and the disputed amount counts as not agreed (Art. 56.15).
- Silence means the company wins. If the reasoned decision is not sent within 20 calendar days, or within the extended term of up to 60 days, the complaint counts as fully satisfied (Art. 56.9).
- A missed deadline can be restored. Within six months the company can still file, with a request to restore the deadline and evidence of valid reasons (Art. 56.3).
When the appeal ends against the company, the agreed amount, with penalties and late interest if any, is due within 10 working days (Art. 57.3).
Court
The company may go to court at any time after receiving the decision, within the limitation periods of Article 102; a decision challenged in court is no longer open to the administrative appeal (Art. 56.18). After an administrative appeal, the claim is filed within one month of the day the appeal ends (Art. 56.19). While the court case runs, the amount counts as not agreed until the judgment takes legal effect (Art. 56.18).
The martial-law option: pay within 30 days, no fines
For documentary audits resumed or started from 1 August 2023 and finished before martial law ends, a company that pays the assessed tax within 30 calendar days of receiving the tax notice-decision has the fines on that amount cancelled, and no late interest is charged. The amount paid this way can no longer be appealed (Tax Code, Section XX, Subsection 10, para. 69.37). This suits cases where the audit finding is right and the dispute is only about the fines.
For the wider tax picture of a foreign-owned company, see how a foreigner registers a company in Ukraine and the full list in the guides hub. If the case reaches court, legal.ua handles appeals against tax authority decisions and support during tax audits.
Frequently asked questions
How long does a company have to object to a tax audit report in Ukraine?
Ten working days from the day after the company receives the audit report. Objections, additional documents and explanations go to the tax office that ran the audit and become part of the audit file (Tax Code of Ukraine, Art. 86.7).
What is the deadline to appeal a tax notice-decision in Ukraine?
A complaint to the higher tax authority is filed within 10 working days after the company receives the tax notice-decision. A late complaint can still be filed within six months with a request to restore the deadline, which is granted if the reasons are found valid (Tax Code, Art. 56.3).
Does the company have to pay the assessed tax while the complaint is pending?
A complaint filed on time suspends the obligation until the administrative appeal ends, and the disputed amount counts as not agreed. Once the appeal ends, the agreed amount, with penalties and late interest if any, is due within 10 working days (Tax Code, Arts. 56.15 and 57.3).
What happens if the tax authority does not answer the complaint in time?
The authority must send a reasoned decision within 20 calendar days of receiving the complaint, or within an extended term of up to 60 calendar days if it notifies the company before the 20 days run out. If no decision is sent in time, the complaint counts as fully satisfied in the company's favour (Tax Code, Arts. 56.8 and 56.9).
Can penalties be avoided by paying the tax quickly during martial law?
Yes, for audits resumed or started from 1 August 2023 and finished before martial law ends. If the tax assessed in the notice-decision is paid within 30 calendar days of receiving it, the fines on that amount are cancelled and no late interest is charged. An amount paid this way can no longer be appealed (Tax Code, Section XX, Subsection 10, para. 69.37).
Send Key Solutions the audit report or tax notice-decision and the date the company received it. A tax adviser checks which deadline is running, drafts the objections or the complaint and lists the documents to attach.
To ask us first, use the question form on the Ukraine For ALL home page or write to info@ua4all.org.
Primary sources
Facts on this page were checked against the primary source on 22 October 2026.
- Tax Code of Ukraine No. 2755-VI, Arts. 42.4, 56.3, 56.8, 56.9, 56.15, 56.17, 56.18, 56.19, 57.3, 77.4, 81.1, 86.7, 86.8; Section XX, Subsection 10, para. 69.37 (consolidated text as of 17 September 2026)
