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Documentary Audit

On Certain Aspects of Conducting an Unscheduled Documentary Audit

11/23/2025
Documentary Audit

We draw your attention to the fact that the basis for deregistering a legal entity with the controlling authorities is the receipt from the state registrar or another registration authority of a notification or documentary confirmation of the state registration of the termination of such legal entity.

The procedure for deregistering taxpayers with controlling authorities is approved by the Order of the Ministry of Finance of Ukraine dated 09.12.2011 No. 1588.

In particular, a taxpayer is required to notify the controlling authority at their place of registration about liquidation or reorganization within three working days from the date of adopting the corresponding decision (except in cases where this obligation is assigned by law to the state registration authority).

In the event of liquidation or reorganization of a taxpayer, the date on which the grounds arise for the controlling authorities to begin the relevant procedures is the date of receipt of the first of the following documents (information), in particular:

  • data from the Unified State Register (USR) on the decision of the founders (participants) of a legal entity or its authorized governing body regarding its termination;
  • data from the USR on the termination (closure) of a separate subdivision;
  • data from the USR on the decision of the authorized governing body (person) of a legal entity established under the legislation of a foreign state regarding the termination of the separate subdivision of such legal entity.

During tax control measures related to the liquidation or reorganization of a taxpayer or to the termination of a separate subdivision of a legal entity established under foreign legislation, the controlling authorities organize and plan such measures in a way that ensures that tax obligations are assessed and delivered to the person responsible for their settlement no later than the deadline set for creditors to submit their claims.

An unscheduled documentary audit is conducted, in particular, in cases where the procedure of reorganization of a legal entity begins (except for transformation), in cases of its liquidation or termination of business activities by a sole proprietor, as well as the closure of a permanent establishment or separate subdivision of a legal entity, including a foreign company or organization; the initiation of bankruptcy proceedings of a taxpayer; or the submission of an application for deregistration.

The decision to conduct an unscheduled documentary audit is made by the head (or their deputy or authorized person) of the controlling authority and is formalized by the corresponding order.

Thus, the controlling authority has the right to appoint and conduct a documentary audit of a legal entity or its separate subdivision if the established grounds exist and taking into account the limitation periods provided for in the Tax Code of Ukraine.