Meeting between EBA member companies and the leadership of the Main Department of the State Tax Service in the Lviv Region

Tax issues should never become a business crisis.

That requires a systematic approach: maintaining proper documentation, understanding procedures, knowing your rights, and making effective use of the available communication channels with the tax authorities.

These practical aspects were at the center of a meeting between member companies of the European Business Association and the leadership of the Main Department of the State Tax Service in the Lviv Region, organized by the Western Ukrainian Office of the EBA as part of the Law and Tax Committee.

The discussion featured Mykola Nykytiuk, Head of the Main Department of the State Tax Service in the Lviv Region, together with the heads of key specialized divisions.

📌 Key takeaways for businesses:

🔹 1. Make sure your company is prepared for tax audits

Oleh Rushchyshyn, Deputy Head of the Tax Audit Department, shared practical insights into scheduled and unscheduled documentary tax audits under martial law.

Companies should regularly review:
▪️ primary accounting documents;
▪️ contracts with counterparties;
▪️ acceptance certificates and service completion records;
▪️ supporting evidence confirming the authenticity of business transactions;
▪️ document retention periods;
▪️ designated employees responsible for communication with tax authorities.

A key takeaway: many risks arise not from the transaction itself, but from insufficient documentation or delayed responses to official requests.

🔹 2. Do not overlook administrative appeals

Ihor Kholiavka, Deputy Head of the Legal Support Department, presented the current practice and statistics regarding appeals against decisions made by tax authorities.

For businesses, this serves as an important reminder that administrative appeals can be an effective way to protect their interests before pursuing litigation.

Best practices include:
▪️ meeting appeal deadlines;
▪️ clearly presenting the company’s position;
▪️ providing all relevant documents and supporting evidence;
▪️ substantiating arguments with applicable legislation;
▪️ preparing appeals well in advance.

Participants also discussed the development of tax mediation as an alternative mechanism for resolving disputes more efficiently and without lengthy court proceedings.

🔹 3. Keep transfer pricing under control

Olena Harasymiak, Head of the Transfer Pricing Department, provided practical guidance on transfer pricing regulations, documentation requirements, and reporting obligations for controlled transactions.

Companies involved in controlled transactions should pay particular attention to:
▪️ timely submission of Controlled Transactions Reports;
▪️ preparation of transfer pricing documentation;
▪️ accurate identification of controlled transactions;
▪️ demonstrating compliance with the arm’s length principle;
▪️ reviewing common reporting mistakes before submission.

Preventive work is especially valuable in this area: identifying potential risks during the preparation stage is far more effective than addressing them during an audit.

🔹 4. Make full use of the State Tax Service’s digital services

Mykola Nykytiuk emphasized the importance of partnership with the business community, digital transformation, and transparent communication.

Participants explored the capabilities of:
▪️ the Taxpayer’s Electronic Cabinet;
▪️ electronic correspondence with tax authorities;
▪️ the Tax Consultants Office;
▪️ the Tax Communication Platform;
▪️ dedicated hotlines.

These digital tools help businesses obtain consultations more quickly, submit documents electronically, monitor important information, and resolve many issues without visiting tax offices in person.

📌 The main takeaway:

Tax security begins long before an audit or a disputed tax decision. It starts with well-maintained documentation, strong internal processes, a clear understanding of legal procedures, and timely communication with the tax authorities.

We sincerely thank Mykola Nykytiuk, Oleh Rushchyshyn, Ihor Kholiavka, Olena Harasymiak, and the entire team of the Main Department of the State Tax Service in the Lviv Region for their openness, practical insights, and willingness to engage with the business community.

Special thanks to Andrii Salo, Chair of the Law and Tax Committee of the Western Ukrainian Office of the European Business Association, for his professional moderation, strong focus on business priorities, and thoughtful facilitation of the discussion.

The Western Ukrainian Office of the European Business Association will continue to foster constructive dialogue between businesses and public authorities.

A strong business environment begins where there are clear rules, responsible communication, and a genuine willingness to listen to one another.