- July 13, 2025
- Posted by: АРОУ
- Category: Publications
Tax disputes are a complex and multi-stage process that requires taxpayers to have a deep understanding of legislation and experience in tax legal relations. One of the most common reasons for such disputes is the tax notification-decision (TND), which may result from a tax audit or other control measures. If you believe that the actions of the tax authority are unlawful and the TND contradicts the law, lawyers at AROU are ready to help you prepare a claim and represent your interests in court.
What is a tax notification-decision (TND)
A tax notification-decision is a document issued by the tax authority following an audit. It states the amount of additional tax liability or imposes penalties for violating tax laws. However, such decisions can be challenged in court if the taxpayer believes they were issued unlawfully or with legal violations.
Declaring actions of the tax authority unlawful
The tax authority may violate the law during audits and decision-making. For example:
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Incorrect evaluation of factual circumstances
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Exceeding its powers
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Violating established procedures
Our lawyers will help you draft an administrative claim to declare the actions unlawful and cancel the tax decision if violations occurred during the audit.
Why it is important to act quickly
A TND can only be appealed within a specific period, after which it becomes legally binding. Therefore, it is crucial to promptly contact an experienced lawyer to assess the situation and prepare the necessary documents.
How the TND cancellation process works
The procedure begins with submitting an administrative claim to the court. In the claim, it must be proven that the actions of the tax authority were unlawful and the decision illegal. Our lawyers will assist in:
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Assessing the legality of the TND
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Forming a legal position and defense strategy
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Preparing evidence, including audit report analysis and related documents
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Filing the claim and representing the client at all stages of the process
Key aspects of preparing the claim
The success of the case depends on:
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Identifying unlawful actions by the tax authority
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Providing legal reasoning with references to applicable laws
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Highlighting procedural violations or incorrect assessments during the audit
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Demonstrating violations of tax legislation in issuing the TND
Each case is unique, so we develop a tailored strategy for every client based on the specifics of their tax relations.
Advantages of working with AROU lawyers
Our legal team has years of experience in resolving tax disputes and offers a full range of legal services, including:
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Situation analysis and consultations on the prospects of court appeals
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Preparation of an administrative claim to declare actions unlawful and cancel the TND
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Court representation at all stages
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Drafting documents for tax audits or responding to tax authority control actions
If you wish to appeal a tax notification-decision or believe the tax authority acted unlawfully during the audit, the legal team at AROU is ready to help. Contact us for a consultation, and our lawyers will provide qualified legal support at every stage.

