The Law on Partial Restoration of Documentary Tax Audits has come into effect


On December 8, 2023, Law No. 3453-IX on the partial reinstatement of documentary tax audits came into effect. This law was officially published on December 7.

The State Tax Service explained that the new law regulates the specifics of conducting audits in areas of armed conflict and temporarily occupied territories annexed by the Russian Federation. It also outlines the conditions for conducting tax audits (secured access). Additionally, criteria for including taxpayers in the schedule of documentary planned audits from December 1, 2023, to December 31, 2024, with monthly adjustments, have been established.

"A document sent by the regulatory body to the electronic cabinet is considered delivered to the taxpayer if it is formed in accordance with the requirements of the laws of Ukraine 'On Electronic Documents and Electronic Document Management' and 'On Electronic Trust Services'," noted the tax service. From December 1, 2023, to December 31, 2024, only the following may be included in the schedule of documentary planned audits:

  • Taxpayers engaged in the production and/or sale of excisable goods;
  • Taxpayers engaged in the organization and conduct of gambling activities in Ukraine (gambling business);
  • Taxpayers providing financial and payment services;
  • Non-residents conducting activities in Ukraine through separate units, including permanent representations and/or separate units, particularly permanent representations of non-residents meeting one of the criteria defined by law;
  • Other taxpayers meeting one of the criteria defined by law based on 2021 performance indicators.

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