Documentary audits: types and timing

The controlling authorities have the right to conduct in-house, documentary (scheduled or unscheduled; on-site or off-site) and actual inspections.

The procedure for conducting documentary scheduled audits is set forth in Article 77 of the TCU.

Thus, the following timeframes are set for documentary tax audits:

- for large taxpayers - 30 business days;

- for small businesses - 10 business days;

- for other taxpayers - 20 business days.

Extension of the audit periods specified in Article 77 of the Tax Code is possible by decision of the head (his deputy or authorized person) of the tax authority for no more than 15 business days for large taxpayers, no more than 5 business days for small businesses, and no more than 10 business days for other taxpayers.

If the taxpayer or its legal representatives refuse to sign the act (certificate), the officials of the controlling authority shall draw up a relevant act certifying the fact of such refusal.

The procedure for conducting documentary unscheduled tax audits is set forth in Article 78 of the Tax Code. The duration of documentary unscheduled audits should not exceed:

- 15 business days - for large taxpayers;

- 10 business days - for other taxpayers;

- 5 business days for small businesses.

Extension of the period for documentary unscheduled audits is possible by decision of the head (his deputy or authorized person) of the tax authority: no more than 10 business days for large taxpayers; no more than 2 business days for small businesses; no more than 5 business days for other taxpayers.

The results of audits are formalized in the form of an act or certificate signed by tax officials and taxpayers or their legal representatives (if any).

The act (certificate) of a documentary off-site audit, as defined by Article 79 of the Tax Code, is drawn up in duplicate, signed by the officials of the tax authority who conducted the audit, and registered with the tax authority within 5 business days from the day following the day of expiration of the period established for the audit (for taxpayers with branches and/or consolidated taxpayers - within 10 business days).

The act (certificate) of a documentary on-site inspection, as defined in Article 78 of the TCU, is drawn up in duplicate, signed by the officials of the tax authority who conducted the inspection, and registered with the tax authority within 5 business days from the day following the day of expiration of the period established for the inspection (for taxpayers with branches and/or consolidated payments - within 10 business days).