Support during tax audits

The outcome of an audit is largely settled before it ends: by admitting the inspectors correctly, by keeping the scope and the deadlines under control, and by well-prepared objections to the report.

When to get in touch

• an order or notice of a scheduled audit has arrived
• an unscheduled or on-site audit has begun
• a request for information and documents has been received
• an audit report with additional charges has been issued

What the lawyer does

• checks the grounds for ordering the audit (Articles 77 and 78 of the Tax Code) and the form of the order and the authorisation
• handles the admission of the inspectors and records how the audit proceeds
• keeps the scope and the duration of the audit under control (Article 82 of the Code)
• organises the production of documents and explanations, and nothing beyond that
• prepares objections to the report within 10 working days (paragraph 86.7) and attends their consideration
• builds the position for challenging the assessment notice that follows

Legal basis

The types of audit are set out in Article 75 of the Tax Code of Ukraine: desk audits (Article 76), scheduled documentary audits (Article 77) and unscheduled ones (Article 78), off-site audits (Article 79) and on-site audits (Article 80). The conditions for admitting officials are set out in Article 81; the duration in Article 82; and the recording of results and objections to the report in Article 86. During martial law the special rules in paragraph 69 of subsection 10 of section XX of the Code apply.

Tax legislation and case law change frequently, and some provisions apply only for the period of martial law. This page reflects the position as of August 2026.

Frequently asked questions

Can the inspectors be refused admission?

Refusing admission is lawful only where the conditions of Article 81 of the Tax Code are not met (a missing or defective order, authorisation or official identification); otherwise refusing admission creates risks for the taxpayer.

Will the court quash the assessment because of a procedural breach?

On the settled practice of the Supreme Court, what counts are procedural breaches that affected, or could objectively have affected, the correctness of the findings; once the inspectors have in fact been admitted the order can no longer be challenged separately — the breaches are raised when the assessment notice is challenged.

Need legal assistance? Call us or leave a request — a lawyer will contact you and explain what to do in your situation.