Type of Audit, Legal Basis and Taxpayer Rights

Desk, documentary and factual audits differ in their legal basis and subject matter. For a documentary audit, management checks the order, referral or notice, details of the officials, the period and taxes covered by the control. For a planned audit, the current State Tax Service audit schedule is also checked as at the start date.

A taxpayer has the rights provided by the Tax Code: to receive properly executed documents, provide explanations and evidence, receive an audit report or certificate, submit objections and appeal decisions. A lawyer explains the deadline for the specific action and identifies evidence that the deadline has been met.

In 2026, the State Tax Service updated its audit schedule during the year. The owner should therefore check the version actually in force on the relevant date. For companies in territories subject to special wartime rules, the tax consultant separately assesses the applicable transitional provisions.

During the audit, management continues to run the ordinary business: managers handle sales, the accountant pays suppliers, processes payroll and files current reporting. Documents for the audit period are separated from new business matters. This helps the accounting team meet current obligations while responding to official requests on time.

Preparation of Documents and Communication with the State Tax Service

At the start, UBC specialists create a register of documents requested or expected for the audit. Each item is assigned an owner, source and delivery date. The accountant prepares accounting registers and tax returns, while the lawyer checks contracts, powers of attorney and the legal basis of the transactions. Management sees which evidence is complete and what still needs to be obtained.

Explanations are prepared for specific facts rather than as general descriptions of the business. Each amount or transaction is linked to the relevant agreement, primary document, payment, accounting entry and tax return. Where a question involves a counterparty, the company uses the documents it actually has and does not replace missing evidence with assumptions.

Official communication is kept through agreed channels. Electronic submissions are confirmed by receipts and acceptance statuses; paper submissions are evidenced by a receipt stamp or another legally recognised proof of delivery. The company retains a complete copy of the package sent to the tax authority.

Audit Report, Objections and Further Appeal

After the audit report is received, UBC specialists compare each conclusion with the documents, tax returns and legal rules. The owner receives a table showing the issue, amount, evidence, legal position, deadline and recommended next step. This allows management to see which findings can be resolved with additional evidence and which require formal objection or appeal.

Objections are prepared around the specific conclusions of the audit report. The lawyer and tax consultant select the documents and rules supporting the company's position and ensure that the submission deadline is met. If a tax notice-decision follows, the available administrative and judicial options are assessed separately.

UBC can support one stage of the audit or the entire process from preparation through to appeal. The fee depends on the tax, period, volume of transactions, number of requests, amount in dispute and required procedural work. The scope and priority actions are agreed before work begins.

For an initial assessment, provide the State Tax Service document, the relevant tax returns, trial balances and a short description of the disputed transactions. Management receives a clear position on each issue and a list of evidence supporting it.

After the audit report, the owner assesses the potential additional tax amount and the effect of the dispute on bank accounts, counterparties and future reporting. If the issue concerns a recurring agreement or accounting method, the accountant and lawyer immediately correct the accounting and documents for future periods. The owner obtains a more robust tax position for subsequent similar transactions.

For a material amount, the owner separately compares administrative and judicial appeal, deadlines for payment of an agreed liability and defence costs. The lawyer explains which evidence the company already has and which State Tax Service findings can be challenged by documents and legal provisions. The owner decides with reference to the amount in dispute, deadlines and the realistic prospects of defending the position.

Before a planned audit begins, the owner should review the largest tax amounts and agreements for the period likely to be examined. The accountant focuses on VAT, corporate income tax, payroll taxes and major counterparty settlements. The lawyer reviews agreements and corporate authority. This preparation gives management time to correct ordinary accounting errors under the procedure provided by law and gather evidence of actual transactions.