Analytical monitoring

Tax disputes are increasingly going beyond the administrative process and moving into the criminal sphere — without audits and agreed obligations. This trend was analyzed by EQUITY partners Vyacheslav Krahlevych and Bohdan Slobodian for the «TOP 50 Leading Law Firms of Ukraine 2026.»

Key highlights:

• the use of analytical reports instead of tax notices;
• initiation of criminal proceedings without conducting tax audits and establishing tax debt;
• the position of the Supreme Court on the inadmissibility of using analytical materials as evidence;
• the first court decisions in which suspicions are dismissed due to the absence of an agreed tax notice;
• the consequences of such practice for the investment climate and legal certainty of business.