I had the pleasure of speaking at the meeting of the Committee on Tax and Customs Law of the Ukrainian Bar Association on the topic of canceling the moratorium on tax audits.
The current situation is such that starting from 8 December 2023 the moratorium on tax audits practically has not been in existence.
Tax authorities were given back almost all the possibilities for conducting tax audits that they had had before the introduction of the "coronavirus” moratorium on tax audits in March 2020. The latter gradually grew into a "military" moratorium on tax audits.
From 8 December 2023 onwards only some minor manifestations of the previously famous moratorium remains to exist, which concern:
- Restrictions on conducting tax audits of individual entrepreneurs of the first and second groups until 1 December 2024;
- Restrictions on conducting tax audits of taxpayers whose tax addresses are temporarily occupied territories, places of military actions or possible places of military actions; and
- Limitation of the scope of scheduled documentary tax audits to certain categories of taxpayers listed in the law until 31 December 2024. At the same time, such categories listed in the law cover a very significant share of taxpayers who may be subject to scheduled tax audits.
Since one of the grounds for conducting a scheduled tax audit is nowadays a low burden of corporate income tax, in order to understand the risks of undergoing the scheduled audit, it is worthwhile for taxpayers to familiarize themselves with the data on the tax burden in the relevant industries. Such data are available on the official website of the State Tax Service of Ukraine at the following link: https://tax.gov.ua/diyalnist-/rezalt/736958.html?fbclid=IwAR2yMavFMtihmn4GI9-ADt5nIjqWtePindAEZBjBmubox75_eebJljF9Rgg
