The time limits for filing a complaint with a superior tax body have not changed (10 business days). However, if there are good reasons, a taxpayer may, within 6 months from the date such 10-day period expires, file with a tax body a request for renewing the missed time limit to file a complaint. Such a request must be accompanied by documents confirming that the reasons for missing this time limit are justified.
Thus, a non-resident operating in Ukraine through its separate units, including permanent establishments, may appeal against a tax body’s decision in an administrative manner. A non-resident may file a complaint within 10 business from the date of the tax body's action / omission to act or decision.
A non-resident may appeal against (1) the decision on its registration for taxation purposes and (2) tax notice decisions concerning it. The general procedure shall apply to the review of complaints