New Procedure for Desk Audits by the State Tax Service (STS)

The State Tax Service has approved a new procedure for the organization and conduct by supervisory authorities of desk audits of tax reporting and certain reporting of financial agents (excluding transfer pricing reporting) by Order No. 4 dated January 6, 2026.

The general procedure defines the basic principles for organizing and conducting desk audits of tax reporting for the following taxes and charges:

• VAT
• Excise tax
• Corporate income tax
• Single tax
• Personal income tax (PIT)
• Unified social contribution (USC)
• Military levy
• Rent payments
• Environmental tax
• Land fee
• Real estate tax other than land
• Transport tax
• Tourist tax
• Fee for parking spaces for vehicles
• Part of net profit (income)
• Dividends on the state-owned share

Certain reporting of financial agents regarding compliance with the requirements set out under Article 393 of the Tax Code of Ukraine (hereinafter — the TCU), namely with respect to:

• identified errors (violations) in tax declarations submitted by taxpayers;
• timeliness of submission of tax declarations, calculations, and reports by taxpayers;
• timeliness of submission of an application for registration of financial agents in accordance with Article 393 of the TCU;
• timeliness of submission by financial agents of reports on reportable accounts and corrected reports on reportable accounts;
• timeliness of responses by financial agents to requests (notifications) of the supervisory authority sent in cases specified under Article 393 of the TCU;
• violations of deadlines for registration of tax invoices and adjustment calculations in the Unified Register of Tax Invoices (URTI);
• violations of deadlines for registration of excise invoices and excise invoice adjustment calculations in the Unified Register of Excise Invoices (UREI);
• timeliness of payment of the agreed amount of tax (monetary) liability;
• completeness of tax accrual and timeliness of tax payment in cases where a Diia City resident does not meet the requirements;
• legality and completeness of the declared amount of PIT to be refunded from the budget, including in connection with the application of the right to a tax rebate.

All tax reporting submitted by taxpayers and registered with the supervisory authority is subject to desk audit on a continuous basis. The taxpayer’s consent to the audit and their presence during the desk audit are not required.

The time limit for conducting desk audits of tax reporting by the STS is 30 calendar days following the last day of the statutory deadline for submitting a tax declaration or amended calculation, or—if such documents are submitted later—following the day of their actual submission.

A desk audit of a tax declaration or amended calculation that includes an application for a budget VAT refund is conducted within 20 calendar days following the statutory deadline for submission of the tax declaration or amended calculation, or—if submitted later—following the day of actual submission.

The duration of a desk audit for taxpayers with a high level of voluntary compliance with tax legislation, for the period of their inclusion in the List of Taxpayers with a High Level of Voluntary Compliance, is 5 business days.A desk audit is conducted exclusively on the basis of data from:

• the taxpayer’s tax reporting, including reporting equivalent to a tax declaration;
• the Unified Register of Tax Invoices (URTI);
• the electronic VAT administration system;
• the Unified Register of Excise Invoices (UREI);

the electronic system for administration of fuel and ethyl alcohol sales;the Unified Register of Licensees and Fuel Circulation Locations;the Unified Register of Licensees for production and circulation of ethyl alcohol, spirit distillates, alcoholic beverages, tobacco products, tobacco raw materials, and liquids used in electronic cigarettes;the Electronic System for the Circulation of Alcoholic Beverages, Tobacco Products, and Liquids Used in Electronic Cigarettes (effective from January 1, 2026);

• customs declarations;the data accounting system of cash registers (RRO Data Accounting System);
• information on payment of the agreed amount of tax (monetary) liability stored and processed in the “Tax Block” Integrated Computer System.

If violations are identified as a result of a desk audit, an act on the results of the desk audit is drawn up in two copies. The act is signed by the officials of the supervisory authority who conducted the audit and, after registration with the supervisory authority, is handed over or sent for signature to the taxpayer within three business days in accordance with the established procedure.

The Act must include the following mandatory sections:

I. “Information used during the audit” — indicating the list of information sources used during the audit;

II. “Findings during the audit” — describing the violations identified during the audit, with references to the relevant paragraphs, subparagraphs, clauses, and articles of the Tax Code of Ukraine and other legislative and regulatory acts that were violated;

III. “Conclusion” — providing a brief summary of the violations identified, with references to the relevant provisions of the Tax Code of Ukraine and other legislative and regulatory acts, as well as indicating the liability предусмотрена for such violations.