Law No. ZRU-1183: if a business objects to a tax-authority account freeze, the court decides — the application must be filed within three days

A new law changes how a taxpayer's bank account operations are suspended. If an entrepreneur objects to the tax authority's decision, the tax authority must go to court, and the court settles the dispute.

Law No. ZRU-1183 was adopted on 20 October 2026 and takes effect on the day of its official publication. It amends the Tax Code and the Economic Procedural Code. According to reports, its aim is to reduce the regulatory burden on business.

Who suspends operations, and how

• The decision to suspend operations on the accounts of a taxpayer or tax agent is made by the head of the tax authority or their deputy.
• If the taxpayer files an objection, the tax authority must apply to court no later than three days after the objection is submitted.
• Until the court rules, operations on the accounts remain suspended.

What must be attached to the court application

The Economic Procedural Code now sets out the documents the tax authority attaches to its application:

• evidence of the violation that was the ground for the suspension;
• confirmation that a notice was sent to the taxpayer;
• the taxpayer's objection.

Lifting the suspension

If the taxpayer removes the circumstances that led to the suspension, the tax authority cancels its decision.

What this means in practice. If the tax authority has frozen your account and you disagree, file your objection in writing and keep proof of submission. The tax authority must take the dispute to court within three days. However, the account stays frozen until the court rules. If the ground for the freeze genuinely exists, the fastest route is to remove it, after which the decision is cancelled.

Photo: Solijonovm1996, Wikimedia Commons (CC BY-SA 4.0)