Tax audits in Ukraine in 2026: what businesses need to know

A tax audit does not always begin with inspectors at the door. A desk audit is carried out remotely, a scheduled audit is announced in advance, while an on-site (factual) inspection can start without warning right in a shop, office, restaurant, warehouse or other business facility.

To protect the business, you need to understand which type of audit is under way, check the inspectors’ documents and properly record which documents you hand over.

Types of tax audits

Article 75 of the Tax Code of Ukraine provides for three types of audits: desk, documentary and on-site (factual).

Desk audit

The State Tax Service (STS) conducts it on its own premises, without an order from the head of the tax authority and without visiting the taxpayer (Article 76 of the Tax Code). The tax authority analyses tax returns, data from the Unified Register of VAT Invoices, electronic administration systems, cash registers (RRO/PRRO) and other information databases.

It most often checks:

• whether reports were filed on time;
• whether reported figures are correct;
• deadlines for registering VAT invoices;
• whether agreed tax liabilities were paid on time.

Scheduled documentary audit

It is carried out if the taxpayer is included in the STS audit schedule (Article 77 of the Tax Code). The annual schedule is published on the STS website by 25 December of the preceding year and updated every quarter. In 2026 it has already been updated several times, so check the current version.

The STS must send or hand over a copy of the order and a written notice of the start date no later than 10 calendar days before the audit begins (paragraph 77.4 of the Tax Code).

Unscheduled documentary audit

It is not part of the schedule and may only take place on the grounds listed in paragraph 78.1 of the Tax Code. For example:

• the tax authority found inaccurate data in a tax return and the taxpayer did not properly answer the STS request (subpara. 78.1.4);
• reorganisation or liquidation of a legal entity, or termination of a sole proprietor (FOP) (subpara. 78.1.7);
• a VAT refund has been claimed (subpara. 78.1.8);
• there is information that wages are paid without taxation, including to unregistered workers (subpara. 78.1.13);
• the taxpayer did not provide information requested as part of a cross-check (subpara. 78.1.19).

The order must state a specific ground from this list, not just a general reference to the Tax Code. How to respond to a request so as not to give grounds for such an audit is explained in our article on requests from the tax authority.

On-site (factual) inspection

It is carried out at the place of business, without warning. It most often covers:

• use of RRO/PRRO;
• issuing fiscal receipts;
• cash discipline;
• inventory accounting;
• licences and excise goods;
• registration of employees.

Even before presenting documents, an inspector may make a test purchase. More on this in our article on unannounced on-site tax inspections.

What to check before admitting the inspectors

Before a documentary field audit or an on-site inspection, STS officials must present (Article 81 of the Tax Code):

1. the inspection assignment;
2. a copy of the order;
3. the official ID cards of the persons named in the assignment.

In the documents, check:

• the taxpayer’s name and details;
• the address of the facility;
• the type, subject and ground of the audit;
• the period under audit;
• the start date and duration;
• the names of all inspectors;
• the signature of the authorised official and the seal.

If these documents are not presented or are improperly drawn up, this may be grounds for refusing admission. But an unjustified refusal risks an administrative arrest of property (Article 94 of the Tax Code), so such a decision is best made only after consulting a tax lawyer.

How to act during the audit

Immediately notify the director, the accountant and the lawyer. Appoint one person to communicate with the inspectors.

Do not:

• create physical obstacles;
• give off-the-cuff explanations;
• hand over all of the company’s documents without analysis;
• sign documents without reading them;
• alter or create documents retroactively.

The taxpayer must provide documents that belong to or relate to the subject of the audit (paragraph 85.2 of the Tax Code). It is best to receive every request in writing and hand over copies with a list stating each document’s title, date, number and number of pages.

When the inspectors take copies of documents, they also draw up a list, and a copy is handed to the taxpayer against signature (paragraph 85.7 of the Tax Code).

If the STS claims that the taxpayer refused to provide documents, the inspector must draw up a report in free form listing the documents that were requested (paragraph 85.6 of the Tax Code). That is why your own list and proof of sending documents help a great deal in any later defence.

What to do after receiving the audit report

If the audit finds violations, the STS draws up a report (akt). Refusing to sign it does not cancel the audit results.

When signing, you can write:

“We disagree with the findings of the report. Objections and additional documents will be submitted within the statutory time limit.”

Objections are filed within 10 business days from the day following receipt of the report (paragraph 86.7 of the Tax Code). Attach primary documents, explanations and evidence of procedural breaches.

A tax assessment notice can be challenged administratively or in court (Article 56 of the Tax Code).

How to prepare the business in advance

Before any audit, we recommend:

• looking yourself up in the current audit schedule;
• carrying out a tax audit of your own;
• putting primary documents and contracts in order;
• checking RRO/PRRO, inventory accounting and licences;
• reviewing how employees are registered and your contracts with FOPs (see our article on sole proprietors instead of employees);
• checking the Electronic Cabinet regularly;
• preparing internal instructions for staff;
• choosing a lawyer whom staff will call when the STS arrives.

Conclusion

The most common mistake businesses make is starting to prepare only after receiving an order or when inspectors appear.

It is better to act in advance: carry out an audit, check whether the inspection was lawfully ordered, make sure the inspectors stay within its limits, document every action and challenge unfounded findings in time.

Legal framework

• Tax Code of Ukraine No. 2755-VI — Art. 56 (appeals), Art. 75 (types of audits), Art. 76 (desk audit), Art. 77 (scheduled documentary audit, audit schedule, 10-day notice), para. 78.1 of Art. 78 (grounds for unscheduled audits), Art. 80 (on-site inspection), Art. 81 (admission to audits), Art. 85 (providing documents, lists, report on refusal), para. 86.7 of Art. 86 (objections to the report), Art. 94 (administrative arrest of property)
• Schedule of scheduled documentary audits for 2026 — official STS website

ARGUS Consulting group carries out tax audits, supports clients during STS audits, prepares objections to audit reports and challenges tax assessment notices. See tax dispute support.

Legal framework as of 14.10.2026.