Looking back at 2025 tax audits in Ukraine: key trends and practical takeaways

On 9 April, we hosted a business breakfast, Tax Audits 2025: Key Takeaways, focusing on the latest trends in tax audits, preparation for the audits and challenging the findings of fiscal control. 

Our guests learned practical tips for leveraging the administrative and court proceedings to challenge the findings and for managing key tax risks faced by businesses.

Key tax audit themes 

During our event, we analysed the trends in scheduled and ad-hoc tax audits to reveal a growth in both the number of audits and the amounts assessed. We also discussed the outcomes of challenged tax audit findings considering that a significant share of tax authority rulings is overturned either completely or partially.

We specifically focused on irregularities in the tax audit process as a standalone reason for overturning the findings of the audits and used case studies to demonstrate how the significance of such irregularities gets assessed, in particular, in terms of the reasons for assigning a tax audit, legitimacy of requests, repeat audits and assessment of penalties.

We also analysed some common matters raised by tax authorities in their audits, such as:

• Bad debts written off
• Use of international tax requests by tax authorities in reviewing the taxpayer’s reliance on double taxation treaties in paying income to non-residents
• Discounting of non-current liabilities
• Tax risks arising from marketing costs and assets written off
• Recognition of VAT, PIT and military tax on expenses

To conclude the meeting, PwC team shared practical tips to strengthen the evidence, align tax and financial documentation and manage tax risks in a proactive manner.

Our speakers:  

• Zhanna Brazhnyk, Director, Head of Dispute Resolution practice, Attorney-at-Law  
• Anna Nevmerzhytska, Director, Head of Financial Services & International Tax Solutions practice 
• Inna Andrushchenko, Director, Head of VAT practice 
• Yana Bazia, Senior Manager, Attorney-at-Law 
• Andrii Lytvynenko, Manager, Financial Services and International Tax Solutions, PwC Ukraine 
• Karyna Sahaidak, Senior Associate, Attorney-at-Law  

We would like to thank our guests and speakers for the fruitful discussion and sharing their practical experience.

Learn more about tax dispute resolution in Ukraine with PwC: 
https://www.pwc.com/ua/en/services/legal/services/tax-disputes.html