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Published: · Volodymyr Sokolov, Head of ARGUS Consulting group · tax

Tax assessment notice: what to do after receiving it and how to protect the business

What a tax assessment notice (PPR) is in Ukraine, how to check it, deadlines for payment, administrative and court appeals, and special martial-law rules.

A tax assessment notice (podatkove povidomlennia-rishennia, PPR) is a document by which the tax authority sets the amount of a tax liability, fine or other financial consequence for a taxpayer, or requires changes to its tax reporting.

Unlike an audit report, a PPR directly affects the rights and obligations of a company or sole proprietor (FOP). So once you receive it, record the date of delivery, check the calculations and choose what to do next: pay, appeal to the State Tax Service (STS) or go to court.

What a tax assessment notice is

The Tax Code defines a PPR as a written decision of the tax authority requiring the taxpayer to:

  • pay a monetary obligation determined by the tax authority;
  • pay a penalty;
  • reduce a VAT refund;
  • reduce a negative VAT or corporate income tax amount;
  • make the corresponding changes to its tax reporting;
  • fulfil other requirements provided by law.

A PPR is issued following a documentary, on-site or desk audit, and in other cases where the amount of the obligation must be determined by the tax authority itself.

An audit report only records the inspectors’ position. A PPR is a decision that creates an obligation to pay unless the taxpayer starts an appeal in time.

When the STS issues a PPR

The general rule: a PPR is issued within 15 business days from the day following delivery of the audit report (paragraph 86.8 of the Tax Code of Ukraine).

If the taxpayer filed objections, explanations or additional documents in time, the decision is issued after they are reviewed: within five business days after the commission adopts its conclusion and sends the taxpayer a written reply (subpara. 86.7.5 of the Tax Code).

So objections to the audit report let you influence what the future PPR will say. More in our article on objections to a tax audit report.

What a PPR must contain

The STS uses different PPR forms depending on the type of violation. But a decision must contain at least:

  • the name of the tax authority;
  • the taxpayer’s details;
  • the number and date of the decision;
  • the ground for issuing it;
  • a reference to the audit report;
  • the tax, levy or type of violation;
  • the tax period;
  • the amount of the principal obligation;
  • the amount of the fine;
  • the legal grounds for the assessment;
  • deadlines for payment and appeal;
  • a detailed calculation of the obligation and financial penalties (paragraph 58.1 of the Tax Code).

If the PPR follows a documentary audit and is the basis for financial liability, it must also contain information on circumstances that mitigate, aggravate or exempt from liability (subpara. 58.1.2 of the Tax Code).

The PPR forms and the procedure for sending them were approved by Order of the Ministry of Finance of Ukraine No. 1204 of 28 December 2015. An updated version has applied since 26 February 2026 (amended by Ministry of Finance Order No. 513 of 9 October 2025): new PPR forms, a QR code for payment and clarified grounds for sending.

Why the date of receipt matters

Deadlines for payment and appeal run from the date the PPR is delivered.

The decision may be:

  • handed to the taxpayer or its representative in person;
  • sent by registered mail;
  • delivered to the taxpayer’s Electronic Cabinet.

If an electronic document is delivered after 18:00, the date of delivery is the next business day. If it is delivered on a weekend or public holiday, it is the first business day after that (paragraph 42.4 of the Tax Code).

Do not ignore your mail and Electronic Cabinet. If the post could not deliver a letter because nobody was at the tax address or the letter was refused, the document is deemed delivered on the day stated by the post in the delivery notice (paragraph 42.5 of the Tax Code).

Immediately after receiving a PPR:

  1. keep the envelope, delivery notice or electronic receipt;
  2. record the date of receipt;
  3. work out the last day for payment and appeal;
  4. obtain the audit report, attachments and calculations if you do not have them;
  5. pass the documents to your accountant and tax lawyer.

What to check in a PPR

The total amount alone is not enough. Go through the whole chain that produced the assessment.

Formal details

Check the taxpayer’s details, the number and date of the audit report, the type of tax, the period, the signature of the authorised official and whether the PPR form matches the nature of the violation.

Tax calculation

Check separately:

  • the principal tax amount;
  • the fine;
  • late-payment interest;
  • the periods in which the obligation arose;
  • tax rates;
  • whether the violation is treated as a repeat one;
  • the arithmetic.

Lawfulness of the audit

For your defence, earlier violations matter as much as errors in the PPR itself:

  • no proper ground for the audit;
  • notification procedure breached;
  • inspectors went beyond the subject or period of the audit;
  • primary documents ignored;
  • requests improperly drawn up;
  • non-provision of documents recorded incorrectly (see our article on failure to provide documents during a tax audit);
  • objections filed but not reviewed.

Fault

For a number of tax offences the tax authority must prove the taxpayer’s fault. The PPR and audit materials should show circumstances proving that the taxpayer could have complied with the rules but did not take sufficient measures.

A mere reference to the fact of a violation is not always enough to impose a fine.

How long you have to pay

The general rule: the amount determined by the tax authority must be paid within 10 business days following receipt of the PPR (paragraph 57.3 of the Tax Code).

However, if within this period the taxpayer starts an administrative or court appeal, the amount under appeal need not be paid until it is agreed.

If the PPR is neither paid nor appealed, the obligation becomes agreed. A tax debt may then arise, a tax demand will follow and collection measures may be applied.

Special rule during martial law

For some PPRs issued after documentary audits there is a separate rule (subpara. 69.37 of para. 69 of subsection 10 of section XX of the Tax Code).

If a documentary audit was resumed or started on or after 1 August 2023 and completed before martial law ends or is lifted, the taxpayer may pay the principal tax liability within 30 calendar days from the day following receipt of the PPR.

In that case:

  • the penalties assessed are deemed cancelled;
  • no late-payment interest is charged;
  • no new PPR is issued.

However, a liability paid in this way cannot be appealed later. So before paying, compare the amount of the fine that would be cancelled with your prospects in an administrative or court dispute.

Administrative appeal

A complaint is filed with the higher-level tax authority within 10 business days following receipt of the PPR (paragraph 56.3 of the Tax Code).

In the complaint, state:

  • which decision you are appealing;
  • which STS conclusions are wrong;
  • which legal provisions were breached;
  • the circumstances and evidence in the taxpayer’s favour;
  • the correct calculation of the liability;
  • a request to cancel the PPR in full or in part;
  • that you wish to take part in the review in person, through a representative or by video conference.

Attach the PPR, the audit report, the objections, the STS reply, primary documents, calculations and evidence that documents were provided during the audit.

A complaint filed on time suspends the monetary obligation under appeal. While the administrative appeal is under way, the amount is considered not agreed (paragraph 56.15 of the Tax Code).

The STS must review the complaint within 20 calendar days. This may be extended, but to no more than 60 calendar days, and the taxpayer must be notified before the 20-day period expires. If no reasoned decision is sent in time, the complaint is deemed fully upheld (paragraph 56.9 of the Tax Code).

Court appeal

The taxpayer may go to an administrative court straight away or first appeal the PPR to the STS.

The deadlines are:

  • without an administrative appeal — six months from receipt of the PPR (part 2 of Article 122 of the Code of Administrative Procedure of Ukraine);
  • after a complaint to the STS — one month following the day the administrative appeal ends (paragraph 56.19 of the Tax Code).

In its ruling of 16 July 2025 in case No. 500/2276/24, the Grand Chamber of the Supreme Court confirmed that after an administrative appeal this special one-month period applies, not the general three-month period under the Code of Administrative Procedure.

Once a lawsuit is filed, the monetary obligation remains not agreed until the court decision takes effect (paragraph 56.18 of the Tax Code). So keep proof that the lawsuit was filed and the ruling opening proceedings, and it is advisable to inform the STS.

Typical mistakes after receiving a PPR

Taxpayers most often:

  • miss the 10-day deadline for an administrative appeal;
  • count the deadline from the date the PPR was drawn up rather than delivered;
  • ignore the Electronic Cabinet;
  • appeal only the fine without checking the principal liability;
  • repeat the text of their objections without analysing the commission’s reply;
  • do not provide their own calculation;
  • do not attach evidence of business transactions;
  • wrongly count on 1,095 days to go to court;
  • pay under the special rule of subpara. 69.37 without realising they lose the right to appeal that amount.

Step-by-step plan

After receiving a PPR:

  1. Record the date and method of delivery.
  2. Work out the deadlines for payment and appeal.
  3. Check the form, details and the signatory’s authority.
  4. Compare the PPR with the audit report and the reply to your objections.
  5. Recalculate the principal liability, fine and interest.
  6. Assess procedural violations and the evidence on the merits.
  7. Compare the options: payment, a complaint to the STS or court.
  8. File the chosen document early and keep proof.
  9. Monitor your tax account and correspondence in the Electronic Cabinet.

Conclusion

A PPR should neither be paid automatically nor ignored. First check whether the audit was lawful, whether the calculations are correct, whether the violation was proven and whether the procedure was followed.

The most important thing is not to miss the first 10 business days. That is when a business must decide on its strategy and start an appeal if it disagrees with the STS decision.

ARGUS Consulting group analyses audit reports and tax assessment notices, prepares complaints to the STS, builds the evidence base and supports tax disputes in court. See tax dispute support.

This material is for information only and is not individual legal advice. Legal framework as of 31.10.2026.

This article is for information only and is not individual legal advice. Legislation changes — contact us for a decision on your specific situation.

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