Appealing against decisions / actions of a tax body


Starting from 23 May 2020, the missed time limits for lodging an administrative complaint may be renewed and non-residents now have an opportunity to file complaints.
1. How have the time limits for filing administrative appeals against tax bodies changed?

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.

2. May a non-resident appeal against a tax body’s decision in Ukraine?

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

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