Legal battles with the tax office: number of cases over property tax reaches a record

In Ukraine, the number of court and administrative decisions related to property tax is rapidly increasing. According to the Case Law Database, the average monthly number of such cases nearly doubled compared to 2021, reaching over 500 decisions per month.

Key points: Record statistics: In 2025 the number of court decisions on property tax reached 6 128. Causes of incorrect tax notices: desynchronization due to quarterly data updates by the STS, unresolved archival BTI records through 2013, and erroneous accounting of property in temporarily occupied territories. Lawyers' advice: Don’t rush to go to court immediately; it’s better to file a data reconciliation request or an administrative appeal. Court statistics According to the Unified State Register of Court Decisions, in 2025 the number of court and administrative disputes over property tax hit a record — 6 128 decisions (an average of 510 per month). In the first half of 2026 there were already 3 074 decisions recorded, and the average monthly figure even exceeded last year’s and stands at 512 cases. For comparison: in 2021 only 3 188 decisions were issued (266 per month), in 2022 — 2 712 (226/mo.), in 2023 — 3 389 (282/mo.), and in 2024 — 4 261 (355/mo.). Thus, the prewar figure was almost half of last year’s. Reasons for the surge in lawsuits Disputes over property tax most often arise because citizens receive incorrect tax notices. As Natalia Kozaieva, a private notary of the Kyiv City Notarial District and Head of the NPU branch in Kyiv, explained to RBC-Ukraine, desynchronization occurs at the stage of data transfer to the STS: a notary records a transaction in the state register on the day of signing, while the tax authority receives the information only quarterly. The situation is further complicated by the fact that the tax is assessed for the previous year, the notary adds. Therefore, in 2026 citizens receive tax notices for 2025. Also read: These incomes can’t be hidden from the tax authorities: when there’s a risk of getting a fine In addition, incorrect tax letters can arise for property that was alienated many years ago. Until 2013, the registration of property ownership rights was carried out by the Bureau of Technical Inventory (BTI), Kozaieva notes. However, there is no automatic transfer of those records to the State Register of Rights. As a result, the registry can show both the current record of the new owner and an unresolved archival record at the same time. Problems can also occur for owners of property in temporarily occupied territories or in combat zones. As Danilo Hetmantsev, chair of the Verkhovna Rada Committee on Finance, Tax and Customs Policy, explains, the STS previously mistakenly counted such area when calculating exemptions, causing people to receive incorrect tax notices. Is it worth going to court? Lawyers at the law firm Sayenko Kharenko advise not to ignore an incorrect tax notice, but also say it’s not worth rushing straight to court. The law firm points out that court proceedings take a long time (from 1 year) and involve significant costs for court fees and legal assistance. Instead, it is much simpler and faster to undergo administrative appeal or to file a request with the STS to reconcile data against original documents. After recalculation, the tax authority will issue a new tax notice, and the previous one will be canceled.

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