27.08.2025

Real Transactions — Real Production: Tax Decision Cancelled

Tax issues: Inspections by state tax and fiscal agencies Kyiv region

One of the largest Ukrainian manufacturers of veterinary medicines, premixes, and compound feed — LLC SPE “Ukrzoovetprompostach” — turned to the Business Ombudsman Council. Following the results of an unscheduled audit, the tax authority questioned the reality of certain raw material purchase transactions for 2020–2021.

The company, however, insisted otherwise and submitted primary documents confirming the purchase of raw materials and their use in production. Without these raw materials, the production of goods would have been physically impossible. Moreover, the audit report did not contain any evidence of violations by the company itself — all arguments concerned only its counterparties.

The Business Ombudsman Council took the case into consideration, joined the complaint review at the State Tax Service of Ukraine, and submitted a written position in support of the complainant. We also visited the complainant’s production facilities to better understand the circumstances of the complaint and the specifics of the manufacturing processes. Within just two weeks, we achieved a positive result — the case was successfully resolved!

As a result, the State Tax Service of Ukraine agreed with the Council’s arguments and cancelled the disputed tax decision.

 

After the successful completion of the case, the company left feedback on its cooperation with the Council:

“LLC SPE “Ukrzoovetprompostach” sincerely thanks the team of the Business Ombudsman Council for their professional assistance and support during the appeal of the tax notices-decisions of the Main Department of the State Tax Service in Kyiv region to the State Tax Service of Ukraine.

Thanks to the coordinated and principled work of the Business Ombudsman Council, the State Tax Service of Ukraine listened to the Council’s findings and recommendations and cancelled the tax notices-decisions amounting to over UAH 1 million.”