Statute of limitations: Restrictions for tax audits, application of sanctions, tax documents retention, and the impact of COVID/martial law
The legal regulation of limitation periods for tax audits, tax assessments, the application of penalties, and tax documents retention appears to establish clear timeframes that tax authorities are required to observe separately for each specific action.
However, in practice, calculating these limitation periods has become increasingly complex in recent years due to the COVID-19 pandemic, the full-scale war, and numerous amendments to related legislation – all of which have created significant room for ambiguity, particularly given the interplay and cumulative impact of these factors. Attempts by fiscal authorities to overly expand these timeframes are, however, constrained by specific legal safeguards, and taxpayers should not hesitate to rely on them.
The presentation explores these aspects in detail, including the distinction between the Ukrainian terms “строки” (time limits covering defined periods; limitation periods) and “терміни” (deadlines referring to fixed points in time) – not only in name, but in substance – as well as the true legal meaning of the declared “suspensions” of time during martial law and the pandemic.
You can learn more in the presentation by Senior Partner Alexander Minin, delivered during the AHK Ukraine online event, available in Ukrainian at the link.
Kind regards,
SIMILAR POSTS
SAF-T UA: A temporary deferral for large taxpayers or a strategic comeback? What does the withdrawal of draft law No. 6255 mean? 
1208
Inspections of primary financial monitoring subjects: Will they take place amid two existing ‘moratoriums’?
402
New moratorium on business inspections: Will it actually work or is it just all sizzle and no steak?
1071
Alexander Minin and Ivan Shynkarenko spoke at the АНК Ukraine event “Tax audits of businesses: How to prepare and what to expect”
293
Tax audits: Types, criteria, and grounds for initiation
451
Prepare your business: Licensing procedures resume in 2025, with key reforms in road transport and beyond
869
Business inspections in May 2025: Ukrainian government gradually shortens the list of prohibited inspections during martial law
520
Standard Audit File (SAF-T UA): Is it an actual practical tool or still just an illusion?
4126
Renewal of tax audits: what shall be considered before deciding on allowing the tax authority to conduct the tax audit and during the tax audit?
697
Alexander Minin and Ivan Shynkarenko participated in the round table discussion “Tax and Customs Audits – Practice and Innovations” at AНK Ukraine
1824
Leave a comment