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How long should we keep key documents for tax purposes?
A de facto limitation of tax audits for a “special period” in view of the absence of an obligation to keep documents for such “extended periods”

author: Alexander Minin

10 March, 2025 Exclusive

For years, taxpayers in Ukraine have followed the rule that primary tax documents must be kept for at least three years (1095 days).

However, legislative changes of 2023 somehow went almost unnoticed and extended this period to five years for nearly all major taxpayer categories.

But key questions arise:


  • From what point in time and to which documents does this five-year period apply?

  • How does this align with the three-year general limitation period for tax audits and assessments under Article 102 of the Tax Code?

  • Are there any peculiarities, considering the previous “special period” when certain tax audits have been subject to restrictions due to the COVID-19 and/or martial law?

  • Won't it turn out that the time during which the supporting documents should have been kept is shorter than the periods during which the Tax Code allows for tax audits?


The full version of the article is available in Ukrainian by the link.

 

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