Preparation of tax complaints: fast, compliant and evidence‑based

Planning to file a complaint with the State Tax Service of Ukraine and not sure where to start? We will help you prepare a proper, well‑reasoned and formally correct complaint to increase your chances of a positive outcome and save your time.

Why a well‑prepared complaint matters

• Effectiveness: a properly drafted complaint allows you to receive a response and a fair decision faster.
• Risk mitigation: formal mistakes may lead to your documents being returned or your complaint left without consideration.
• Protection of interests: a complaint is an effective tool to protect your business and your taxpayer rights.

When you should file a complaint

• You disagree with the results of a tax audit or the audit report.
• The tax authority has issued a decision or order that restricts your rights or results in additional payments.
• You believe your rights were violated during administrative proceedings or when penalties were imposed.
• You need to challenge an individual tax consultation or a refusal to provide it.

Preparation stage — what to do first

• Collect documents: copies of the audit report, decisions, correspondence with the tax office, primary documents, payment documents, contracts.
• Clarify deadlines: find out within which period a complaint may be filed (these deadlines are usually set by procedural rules).
• Define the grounds: clearly state why you disagree – factual errors, misapplication of law, procedural violations.
• Gather facts: prepare a chronology of events and a list of evidence supporting your position.

Structure of an effective complaint

• Heading: “Complaint” or “Appeal against the decision (act) of the tax authority”.
• Applicant details: full name or company name, tax ID / EDRPOU code, address, contact details.
• Addressee details: tax authority unit that issued the decision, date and number of the act/notice.
• Statement of facts: brief description of the case with dates and references to documents.
• Legal arguments: facts, evidence and legal provisions that support your position.
• Relief sought: clearly formulated requests (to cancel the decision, cancel penalties, conduct an additional review, etc.).
• Annexes: list of attached documents (copies of acts, contracts, payment documents, correspondence).
• Signature and date.

Practical tips

• Write briefly and to the point, avoid emotional language.
• Refer to specific legal provisions where possible — this strengthens your position.
• Number the annexes and refer to them in the text.
• Provide phone numbers and an email address for quick contact.
• Keep a copy of the complaint with a receipt stamp if filed in person, or send it by registered mail / tracked delivery and keep proof of submission.

Common mistakes

• No evidence or poorly organised evidence.
• Vague or unclear wording of the relief sought.
• Missing the filing deadlines.
• Overly emotional tone or unsubstantiated accusations.
• No signature or contact details.

What we do for you

• Review all available documents and build a legal position.
• Draft a clear, structured complaint with references to documents and legal provisions.
• Prepare a list of evidence and annexes.
• Help you file the complaint correctly and obtain proof of submission.
• If needed, accompany you during the administrative review and prepare responses to requests from the tax authority.

Timeframes and fees

• Express complaint: preparation within 48 hours (short complaint + list of annexes).
• Standard: detailed complaint with legal arguments and document preparation — 3–5 business days.
• Additional options: support during consideration, representation before the commission, preparation of a court appeal.

When you should seek assistance

• The case is complex, involves significant amounts or material business risks.
• You lack time or experience to prepare the documents yourself.
• You want to maximise your chances of success and minimise formal mistakes.

Short pre‑submission checklist

• All evidence and copies of documents are collected.
• Filing deadlines are not missed.
• Requests are clearly formulated.
• Annex list and contact details are prepared.
• Proof of sending or filing is saved.

We are ready to help: send us the necessary documents or describe your situation, and we will prepare a complaint, develop an action plan and advise on the best next steps.
Author – Yuliia Boiko, attorney at the Tax and Customs Law practice of “WINNER” Law Firm.