Ukraine | Tax audits in a new way: major changes for taxpayers


Law 466-ІХ (hereinafter – the Law), which was adopted 16.01.2020, has introduced significant changes to the Tax Code of Ukraine (hereinafter – TCU). Among other things, the Law has changed the legislation governing the procedure for conducting, processing, and calculating amounts of monetary obligations and appealing the results of tax audits.

Previously, it was strictly prohibited by law to make adjustments to the schedule of tax audits by including new taxpayers. Starting from 23.05.2020, the changes came into force, according to which the schedule of tax audits for the current year can be changed twice a year.

The changes have also affected the procedure to submit additional documents by taxpayers, which may be requested during the tax audit by the regulatory authorities. According to the amended provision of the TCU, the regulatory authority must submit a request for copies of documents no later than 5 working days before the end of the audit. This change will prevent the regulatory authority from abusing the right to request the required documents from taxpayers in a period in which it is physically impossible to collect them.

Another important change is that the period for checking and issuing tax notifications and decisions on the payment of personal income tax, a military fee upon payment of wages, has been increased from 3 to 5 years. In addition, tax authorities have obtained the right to get explanations from employers and/or their employees during audits. They also have received the right to carry out unscheduled inspections of previously checked periods in case they receive information about violations from foreign governmental bodies.


The changes introduced by Law 466-IX will have both positive and negative consequences for taxpayers.

Positive aspects:

  • establishment of a deadline for requesting documents from a taxpayer during tax audit
  • improvement of the procedure for appealing the results of tax audit
  • possibility to restore in an administrative manner the deadline for appealing decisions based on the results of an audit

Negative aspects:

  • increase in the frequency of updating the schedule of tax audits
  • expansion of the rights of regulatory authorities during tax audits, the subject of which is the employer’s compliance with labor legislation.



SCHNEIDER GROUP Kyiv experts will be happy to provide you with support in the issues related to tax audits as well as appealing the decision of regulatory authority using their experience and competencies for the success of your business.

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