According to the results of a tax inspection, an inspection report shall be drawn up (in case of detection of violations of the tax legislation in the enterprise’s activity) or a certificate (in the absence of such violations).
After 10 working days from the date when the inspection report was given to the company, the head of the supervisory authority shall issue the tax assessment notice that specifies the violations of the tax legislation and the amount of tax obligations (fines and penalties) that shall be accrued to the company for payment.
If the company does not agree with the accrued tax obligations, it is necessary to appeal against such decisions (tax assessment notice, tax order).
The current legislation of Ukraine (the Tax Code of Ukraine, the Code of Administrative Court Procedure of Ukraine) provides for such options for appealing against the actions of tax authorities as administrative appeal and judicial appeal:
- The administrative appeal is the filing of complaints to the bodies of the State Fiscal Service of Ukraine (to a higher authority). Usually, such appeal is ineffective and is used only for saving time to prepare and file a claim to the court (without charging penalties and fines for failure to pay the accrued tax obligations).
- The judicial appeal is the filing of a claim (suit) to the appropriate administrative court.
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