How tax liabilities are concerted: explanation for the taxpayers

Press service of the State Tax Service of Ukraine, published 27 March 2025 at 12:02 Chapter: News

Tax liability is amount of tax that the taxpayer must pay to the budget. But when is this amount considered final and subject to obligatory payment?

1. When is a tax liability considered concerted?

Tax liability becomes concerted in the following cases:

- If the payer declared tax amount on own, it is considered concerted upon immediately after submitting declaration.

-If tax authority accrued additional tax liabilities after the audit, and the payer does not appeal this decision, this amount becomes concerted 10 working days after receiving tax notification-decision.

Important!  

Amounts of concerted tax liabilities are entered into the taxpayer’s account card automatically.

If discrepancies arise, the taxpayer has a right to initiate reconciliation of reporting data for compliance with information in the State Tax Service’s databases or to appeal decision of the tax authority.

State Tax Service does not collect tax liabilities before the appeal deadline expires.

2. What happens if the payer does not agree to the additional accruals?

If the taxpayer does not agree with accrued amounts, such taxpayer has a right to appeal them:

Administrative appeal (complaint to the State Tax Service)

The taxpayer has 10 working days from the date of receipt of tax notification-decision to submit a complaint to the State Tax Service.

During the complaint review, tax liability is not considered concerted.

If the State Tax Service leaves tax notification-decision unchanged, amount becomes concerted from the date of receipt of the State Tax Service’s decision.

Judicial appeal

If the payer files a lawsuit to the court, tax liability remains un-concerted until the court decision becomes final. However, the mere fact of filing a lawsuit is not grounds for deducting amount from the tax debt.

To do this, it is necessary to obtain the court decision to initiate proceedings (Article 171 of the Code of Administrative Procedure of Ukraine).

Important!

Decision to open proceeding is important legal document that confirms the fact of judicial consideration of a dispute about tax obligations.

It allows the taxpayer to protect rights and avoid automatic collection of amounts until the court makes a final decision. In this case, decision can be sent to the case parties both in a paper form and electronically through the electronic court (Electronic court service). However, the taxpayer’s letter with information about challenging tax obligations is not legally confirmed fact of judicial consideration of the dispute.

If the court cancels tax notification-decision – the tax is not subject to payment.

If the court confirms tax notification-decision – amount becomes concerted from the moment decision becomes legally effective.

3. Why is this important?

- Concerted tax debt must be paid, otherwise financial sanctions and penalties will be charged.

- If the tax liability is not concerted (disputed), it is not subject to forced collection.

Tax authorities’ actions regarding collection of concerted amounts of tax liabilities

Tax authorities have different powers to collect tax liabilities.

What does the Tax Service do??

Sends a demand for the debt payment

If the payer has not paid tax debt within the specified period, the tax authority sends a tax demand (Article 59 of the Tax Code of Ukraine).

Demand contains the debt amount and deadline for its voluntary repayment.

If amount is withdrawn from the payer’s integrated card in connection with the appeal, the tax demand is automatically withdrawn.

If there are any questions regarding reconciliation of tax obligations, contact the controlling authority at the registration place or submit application through the payer’s Electronic cabinet.