From January 1, 2026, taxpayers retain the right to appeal notifications on the results of tax audits. An appeal is submitted in case of disagreement with the conclusions of the tax authority, identified violations, assessed taxes, payments to the budget, and penalties. Starting from 2026, the main changes include the establishment of a more detailed procedure for considering appeals. Appeals against notifications on the results of tax audits are considered within the framework of the appeal procedure, which is aimed at improving the objectivity and quality of consideration of taxpayers' applications. The approach to appealing certain procedural actions of tax authorities has also changed. Previously, appealing certain documents could affect the conduct of a tax audit; however, from 2026, filing an appeal against certain actions of a tax authority is not a ground for suspending a tax audit.
Filing an appeal with the authorized body or applying to the court suspends the enforcement of the notification in the appealed part until a decision is made. An appeal must be submitted within 30 working days from the day following the date of delivery of the notification on the results of the tax audit. The period for submitting an appeal is calculated from the day following the date of delivery of the notification on the results of the tax audit. Depending on the method of submission, the date of filing an appeal with the authorized body shall be considered: 1) In person — the date of registration of the appeal by the authorized body; 2) Through postal or other communication organizations — the date indicated in the acceptance mark by the postal or other communication organization; 3) Electronically — the date of sending through the web portal. The appeal must be signed by the taxpayer or their representative and must contain the justification of the taxpayer's position, references to legal provisions, and supporting documents.
Based on the results of consideration of the appeal, the authorized body shall make one of the following decisions:
leave the notification unchanged and reject the appeal;
cancel the notification in full or in part.
To protect their rights, taxpayers should comply with the appeal deadlines, provide evidence, and properly substantiate their position.