On 5 February, we held a business breakfast “Tax Audit Findings: 2025 Experience” having invited representatives of the Business Ombudsman Council to analyse which types of transactions were in focus of the tax authorities over the past year.
During the event, we discussed the tax audit findings in 2025, the cases handled by PwC lawyers and the Business Ombudsman Council’s inspectors, the recommended evidence base and the protection strategy.
We also dedicated particular attention to the topic of budget refunds — the reasons for rejections, the issue of repeated tax audits and recommendations for effective dispute resolution. We also addressed the specifics of tax audits of transactions involving payments of passive income to non-residents, debt liabilities to non-residents and the use of goods and services in business operations and analysed the statistics of scheduled and unscheduled tax audits.
“In applying their own risk‑based approach, the tax authorities have heavily focused on unscheduled measures. 12,191 unscheduled tax audits conducted in 2025 have resulted in additional tax assessments that were approximately 7.5 times higher than those in 2024. A similar trend will continue in 2026 — the tax authorities are preparing thoroughly for tax audits, conducting preliminary analytical work, gathering information and sending inquiries to target entities where irregularities have already been identified,"
“The 2025 experience proves that taxpayers should be prepared for tax audits and have a strong evidence base. If you have a loan from a non‑resident and do not discount it, you should have evidence of the market level of the interest rate before the audit commences,”
Speakers at the event were Maryna Pavlenchyk and Yuliia Mykhailiuk, Senior Inspectors of the Business Ombudsman Council, Yana Bazia, Senior Manager and Attorney-at-Law at the Dispute Resolution Practice in PwC Legal Ukraine, Karyna Sahaidak and Marharyta Nedashkovska, Senior Consultants and Attorneys-at-Law at the Dispute Resolution Practice in PwC Legal Ukraine.
We sincerely thank our guests and speakers for a productive meeting and a valuable exchange of experience!
Stay tuned for our announcements and continue the dialogue with our Dispute Resolution team.
Contact us
Yana Bazia
Attorney-at-law, Senior Manager, Dispute Resolution practice, Attorneys Association "PwC Legal in Ukraine"
Tel: +380 44 354 0404
