Analytics

Statute of limitations: Restrictions for tax audits, application of sanctions, tax documents retention, and the impact of COVID/martial law

author: Alexander Minin

12 June, 2025 Newsletters

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,

Views 2129