Ukraine's Cabinet of Ministers approved a draft law on Friday, August 14, allowing taxpayers to challenge the actions and inaction of tax officials alongside official decisions.
The Ministry of Finance announced the passage of the bill, titled On Amendments to the Tax Code of Ukraine in Connection with the Adoption of the Law of Ukraine On Administrative Procedure. The measure adjusts tax dispute mechanisms to follow Ukraine's broader administrative procedure legislation while amending both the Tax Code and social insurance collection laws.
Ministry officials stated that aligning tax rules with general administrative standards fulfills commitments under Ukraine's Association Agreement with the European Union.
Tax appeal procedures and deadlines
Under existing legislation, taxpayers were restricted to appealing formal decisions issued by tax authorities. The new draft law expands those rights to cover physical actions and systemic inaction by tax officers.
The bill extends the standard deadline for lodging most tax appeals from 10 working days to 30 calendar days. A limit of 10 working days remains in place for formal tax assessment notifications.
Appeals will now be submitted directly to the specific tax body that took the action or issued the decision, rather than to a higher administrative authority. Complaints regarding tax authority inaction must be submitted within six months from the date the taxpayer became aware of the issue.
Taxpayers who miss an appeal deadline for valid reasons may petition for restoration within 10 working days after the impediment ends, provided the request is filed within one year of the contested decision.
Specialized sector laws will continue to govern dispute procedures involving electronic communications and trade in excisable goods such as fuel, alcohol, and tobacco products.
Single social contribution guarantees
The Ministry of Finance emphasized that identical legal protections will apply to payers of the single social contribution. These protections include rights of appeal against decisions, actions, and inaction, strict timelines for complaint reviews, and a formal mechanism to settle tax arrears during court challenges.
Finance ministry representatives noted that the legislation will increase transparency and administrative efficiency while providing stronger legal protections for citizens and businesses interacting with tax control agencies.
Tax reform benchmarks and military levy
The tax administration bill follows related fiscal decisions passed by Ukrainian lawmakers earlier in the year. On April 7, 2026, the Verkhovna Rada enacted a measure establishing that the 5 percent military levy will end automatically three years after martial law is lifted, returning the tax to its pre-2024 rate of 1.5 percent.
On July 21, the International Monetary Fund published an updated Memorandum on Economic and Financial Policies detailing structural benchmarks for Ukraine. The update split and rescheduled a major tax reform package that was originally scheduled for parliamentary approval before the end of March 2026.
Ukrainian authorities were also reviewing proposals at the end of July to introduce a reconstruction tax designed to replace the 5 percent military levy after fighting concludes.
